On 18 September 2026 WAPFSA addressed an urgent letter to the City of Cape Town and representatives of SANParks, CapeNature and the Cape Peninsula Baboon Management Joint Task Team.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national network of thirty South African organisations, established in 2017 to engage government on matters concerning the conservation and protection of wild animals and the natural environments in which they live. Its members work across animal protection, conservation, environmental justice, law, governance, climate justice and community advocacy. WAPFSA’s positions are informed by robust science, constitutional and environmental law, ethical and compassionate conservation practices, and a commitment to humane coexistence between people and wild animals.
WAPFSA writes to remind the City of Cape Town, SANParks and CapeNature and representatives of the Cape Peninsula Baboon Management Joint Task Team that there is a viable alternative to capturing the Waterfall and Seaforth baboon troops and confining them permanently at the proposed Kogelfontein Urban Wildlife Centre.
The alternative is an appropriately designed and located baboon-proof fence, developed and assessed with the benefit of Dr Dave Gaynor’s expertise, together with the waste-management, monitoring and community measures needed to make the intervention effective.
This document discusses South Africa’s draft National Biodiversity Strategy and Action Plan (NBSAP 2026–2035), highlighting biodiversity conservation issues, global frameworks, and advocacy efforts by the Wildlife Animal Protection Forum South Africa.
South Africa’s Biodiversity Policy Challenges
South Africa’s draft NBSAP 2026–2035 faces criticism for not aligning with global biodiversity goals and global standards like the Kunming-Montreal Framework.
Domestic policies are seen as watering down international commitments, with severe ecosystem threats and declining biodiversity.
Global Biodiversity Framework and International Commitments
The Kunming-Montreal Framework aims to halt biodiversity loss by 2030 but relies on voluntary targets with limited enforcement.
Many global targets, including the Aichi Biodiversity Targets, were not achieved by 2020, due to poor monitoring and lack of national implementation.
Steve Smit, a beloved member of the Wildlife Animal Protection Forum South Africa (WAPFSA) also affectionately known as KwaZulu-Natal’s famous “Monkey Man,” passed away on Wednesday, 12 August 2026, after a brave, well-fought battle with cancer.
His passing has left the global conservation, and KwaZulu Natal communities deeply heartbroken, we collectively mourn a legendary champion for wildlife. Over a span of thirty years, he dedicated his entire life to the protection, rescue, and rehabilitation of urban wildlife, leaving behind an unforgettable legacy as a fierce voice for the voiceless.
Conceptualized in 2017, WAPFSA took shape as a collaborative network in 2018 before gaining full formalization in 2019. However, founding members Michele Pickover, Executive Director of the EMS Foundation, and Steve Smit shared a close professional alliance that extends all the way back to 2003.
Michele Pickover interviewed Steve Smit in 2003 as part of her research report titled: The Environmental Movement in South Africa – An Analysis of Animal Based Issues, Campaigns and Organisations. On page 365 of her report she stated that there were no animal rights organisations in South Africa. Five years later, on the 8 March 2008, Animal Rights Africa (ARA) was officially launched marking an unprecedented milestone in African animal rights advocacy. The two key figures and co-founders of Animal Rights Africa were of course, Steve Smit and Michele Pickover.
Steve Smit and Carol Booth founded the Monkey Helpline in 1995. A dedicated non-profit organisation responding to thousands of rescue call-outs annually across KwaZulu-Natal. The EMS Foundation has played a pivotal role in supporting this successful wildlife rescue and rehabilitation operation by providing substantial financial backing to the Monkey Helpline Rehabilitation and Sanctuary Centre to ensure the long-term survival of rescued Vervet monkeys in South Africa.
Steve Smit was also an important member of the WAPFSA Primate Working Group. This group focuses on the welfare, ethical management, and protection of indigenous primates in South Africa including amongst other, the chacma baboon. Over the past few years Steve Smit has been particularly outspoken against the current chacma baboon management policies adopted on the Cape Peninsula and the Overstrand regions of the Western Cape.
WAPFSA honours the incredible life and profound legacy of our dear friend and colleague Steve Smit. Steve was a legendary, tireless champion, a fierce voice for the voiceless, and a true pillar of ethical conservation in South Africa. While we deeply mourn this monumental loss, his fierce spirit, unwavering dedication, and decades of compassionate activism will forever guide our collective mission to protect the wild. Rest in peace, Steve; your vital work continues through the endless lives you saved and the network you helped build.
The Wildlife Animal Protection Forum South Africa Requests an Urgent Independent Health and Well-Being Assessment for Opal
WAPFSA is hereby politely requesting urgent assistance from Ezemvelo KZN Wildlife, the mandated regulatory authority in KwaZulu-Natal that issues permits regulating the housing, movement, and care of wild animals to ensure compliance with animal welfare and environmental legislation.
WAPFSA is requesting your permission is granted for an urgent in-person independent, professional assessment of Opal’s physical health and wellbeing. The assessment to be carried out at the Natal Zoological Gardens. The independent wildlife experts will be appointed by primate expert members of WAPFSA, the professional details of the experts, the details of the methodology of the assessments and the written results of the assessments will be shared with Ezemvelo KZN Wildlife.
Substantial revision of these Draft Guidelines is required. In addition, the core safeguards governing proof, prevention, authorisation, animal well-being, prohibited methods, monitoring, transparency and enforcement should be contained in binding national Norms and Standards or other enforceable legislation.
The undersigned Members of WAPFSA, therefore, do not support the finalisation of the Draft Guidelines for the Management of Damage-Causing Animals in South Africa in their present form.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) warns that South Africa’s rhinos face a critical tipping point due to escalating poaching and controversial government policies that favour trophy hunting and the commercial wildlife trade.
South Africa stands at a defining moment in the future of rhino conservation. A recent High Court judgment, combined with growing political pressure to revive commercial trade in rhino horn, threatens to fundamentally reshape the country’s conservation model. WAPFSA believes these developments risk undermining decades of progress in combating wildlife crime while placing South Africa in conflict with its constitutional obligations to protect biodiversity for present and future generations.
The illegal killing of rhinos for their horn is thought to be the single greatest threat to the future of both the black rhino and white rhino species. Although poaching remains an immediate threat, WAPFSA believes the greater long-term danger lies in policy decisions that normalise commercial trade in rhino horn and weaken the legal and ethical foundations of rhino conservation. The Wildlife Animal Protection Forum of South Africa (WAPFSA) advocates against commercialization, captive breeding, and trophy hunting of rhino. WAPFSA emphasizes ethical conservation, the intrinsic value of all wild animals, and recommends the phasing out of all rhino, and lion, intensive breeding facilities established for commercial use. The legal stockpiling and sale of rhino horn, and lion bone, drives the illegal international trade and the continued illegal killing of rhino, and lion. WAPFSA argues that South Africa’s domestic rhino horn stockpiles are compromised, unverified, and act as a driver of the illegal international black market. Rhinos are killed because their horn is highly sought after on the black market. The perceived high street value of rhino horn is perpetuated because rhino horn is stockpiled instead of being destroyed.
The reason for this WAPFSA statement is because the future of rhino conservation is at a pivotal turning point. South African, Wicus Diedericks, the owner of a 3000-hectare farm in the Norther Cape Province, called Rockwood Conservation has chosen to intensively breed rhino. This decision despite the well published, textbook disaster of a similar business model, when the primary goal to legalise the international rhino horn trade failed to materialise.
Diedericks also operates “highly regulated Southern White rhino hunting” at his farm. His philosophy “we don’t breed to hunt, we hunt to protect, utilizing funds from these highly controlled hunts to cover the massive security, feeding, and veterinary costs required to protect their herd of over 400 rhino.”
Diedericks is currently in litigation against the South Africa’s Department of Forestry, Fisheries and the Environment (DFFE). He argues, as did John Hume, that maintaining high-tech anti-poaching security and feeding his rhinos costs over R20 million annually, making his breeding operation financially unsustainable without a constant revenue stream. Diedericks is currently attempting to export at least 502 stockpiled horns to buyers.
A report reveals that the Diedericks plans to send rhino horns to multiple locations worldwide, including China, Hong Kong SAR, Japan, Laos, Mongolia, the U.S., and Vietnam, with each receiving between three to five horns. However, the majority of the shipment is intended for a single address in Ontario, Canada raising heightened concerns about the legality and potential impact of such exports.
WAPFSA believes that if the rhino horn trade is legitimised and or even facilitated by the South African court, global market demand for rhino horn risks stimulating demand by creating perceptions of legitimacy within international markets. A previous one-off legal sale of elephant ivory in 2008 was associated with an elephant poaching spike and a dramatic increase in the illegal ivory trade. A legal supply of rhino horn may support a continuation or increase in rhino poaching, endangering the survival of rhino species in South Africa and in neighbouring African states.
To further complicate the present situation, WAPFSA has raised alarms about political appointments within the Department of Forestry, Fisheries and the Environment (DFFE), and has cautioned against the influence of pro-trade and commercial wildlife-utilization lobbies.
To validate WAPFSA’s most recent concerns, pro-rhino trade organisation SUCo-SA have drawn our attention to an internal seven-page DFFE memorandum prepared for Minister Barbara Creecy dated 1 August 2022. The existence of an unpublished internal legal memorandum – now being circulated publicly by organisations advocating commercial rhino horn trade – raises legitimate questions about transparency, policy development and the extent of stakeholder influence over government decision-making.
DFFE’s recent Biodiversity Management Plan for Black and White Rhinoceros has drawn widespread criticism for signalling a policy shift towards facilitating domestic and international rhino horn trade through the use of controversial interpretations of CITES exemptions, despite South Africa’s ability to maintain stronger domestic conservation measures than those required under the Convention.
WAPFSA believes the judgment places excessive reliance on minimum obligations contained in CITES while giving insufficient weight to South Africa’s own constitutional framework and domestic biodiversity legislation. International treaties establish minimum standards. States remain free – and in many circumstances obliged – to adopt stronger domestic protections where necessary to conserve biodiversity and fulfil constitutional obligations.
While the state has exhausted this immediate avenue of appeal, WAPFSA is hopeful that DFFE, now led by recently appointed Minister David Maynier WAPFSA is evaluating its options for a direct petition to the Supreme Court of Appeal.
South Africa now faces a clear choice. It can reinforce constitutional biodiversity governance by rejecting commercial rhino horn trade and strengthening protections for wild rhinos. Or it can return to policies that blur the line between conservation and commerce, increase pressure on already vulnerable populations, and undermine decades of international leadership. WAPFSA believes this is not simply a dispute about wildlife trade. It is a defining test of South Africa’s constitutional commitment to protect biodiversity in the interests of present and future generations.
BACKGROUND INFORMATION
Wildlife Animal Protection Forum of South Africa
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national alliance and collaborative network of 30 non-governmental organisations that advocate for the protection and welfare of wild animals and their natural habitats. Acting as a collective body to lobby various government departments, particularly the Department of Forestry, Fisheries and the Environment (DFFE). Campaigning against the commercial exploitation of wildlife, specifically targeting captive breeding, trophy hunting, wildlife trading, and the commercial sale of animal parts Promoting conservation strategies grounded in ethics, science, and the harmonious co-existence of humans and wildlife.
WAPFSA rejects the proposition that wildlife should be conserved only when it generates commercial returns. South Africa’s Constitution and environmental legislation recognise biodiversity as a public trust to be protected for present and future generations. Conservation cannot be reduced to a commercial business model dependent on the sale of body parts. Rhinos are not financial assets whose survival should depend on maintaining a market in their horns.
Diedericks VS Department of Forestry, Fisheries and the Environment
The international trade in rhino horn has been banned since 1977 under Appendix I of the Convention on International Trade in Endangered Species (CITES). To circumvent this, Diedericks invoked Article VII(5) of the CITES treaty. This exemption dictates that wildlife specimens “bred in captivity” for non-commercial or conservation purposes can be traded under less restrictive permit frameworks. He argued that because South Africa is a CITES signatory, this exemption is automatically part of domestic law, and the government’s blanket refusal to issue his export certificates was illegal.
In April 2023the DFFE officially rejected Diedericks’ applications to export the horns, maintaining that South Africa did not actively implement or recognize the Article VII exemption for commercial rhino trade. Diedericks promptly made an application in the High Court to compel the government to issue permits to export over 500 white rhino horns. He argued that selling ethically trimmed horns would fund his expensive anti-poaching and conservation operations. Diedericks formally sued the state under the Promotion of Administrative Justice Act (PAJA) after provincial authorities denied his export permit applications in April 2023.
On 31 October 2025the Northern Cape High Court in Kimberley ruled in Diedericks’ favour. The judge declared that the CITES captive-bred exemption was indeed enforceable under South African law. The court ordered the provincial government to review Diedericks’ permit applications within seven days.
On 31 October 2025 Dr Dion George, Minister of Forestry, Fisheries and the Environment, called for a principle to move from words to action, from commitment to consequence, and reaffirmed South Africa’s decisive steps to close the captive-bred lion industry, protect abalone under CITES, and oppose any reopening of trade in ivory or rhino horn.
“We extend our congratulations to our valued member Wicus Diedericks and his exceptional legal team on their recent success in the Northern Cape High Court matter against the MEC for Economic Development, Environmental Affairs and Tourism, and Minister Dion George.
This landmark judgement marks a significant milestone for the wildlife sector, affirming the right to the sustainable use and regulated trade of rhino horn. It represents a crucial step forward for conservation, the protection of private property rights, and the responsible management of South Africa’s natural resources.”
In May 2026 while the South African government formulated its appeal, international watchdogs like the Environmental Investigation Agency (EIA) published critical reports. The EIA flagged the lawsuit as a “reckless gambit”, warning that the provided buyer information was inaccurate and that the exports would stimulate the black market and fuel poaching.
In July 2026 the Northern Cape High Court officially dismissed the state’s application for leave to appeal with costs. The court reaffirmed that private breeding operations devoted to conservation have a legal right to fund their high-cost protection efforts through regulated trade.
Rhino Breeding Industry is Deeply Entangled with Organised Crime
Clearly not all rhino breeders are involved in illegal activity, however the South African rhino breeding industry itself has been deeply entangled with organized crime. Investigations reveal that major commercial breeders have used legal domestic permits to harvest horns and covertly funnel them into illegal transnational smuggling networks targeting Southeast Asia.
Hume bred approximately 2,000 southern white rhinos, roughly 15% of the world’s remaining wild population, on his 7,800 hectare Platinum Rhino ranch. John Hume,allegedly ran out of funds to maintain this massive breeding operation and put the entire project up for auction. Allegedly, not a single bid was received for the business at auction. Allegedly, the rhinos were at severe risk of poaching and abandonment. In September 2023 the non-governmental organisation African Parks stepped in to purchase the farm situated in the North West Province of South Africa and approximately 2000 rhinos.
While John Hume’s southern white rhinos achieved unprecedented captive breeding success, critics heavily argued that their intensive, ranch-style confinement reduced their living conditions to that oflivestock. “I am especially pleased to see that the very first translocation of some of the 2,000 white rhinos are going to this important landscape within South Africa, which is a flagship partnership in which communities are making a significant contribution to the conservation of our natural heritage,” says Barbara Creecy, South Africa’s Minister of Forestry, Fisheries and Environment. “On behalf of the Government of South Africa, we were very supportive of African Parks’ plan to purchase and rewild these rhino and remain a key partner in providing technical and scientific advice, and the support needed to carry out this conservation solution in South Africa and on the African continent.”
The other high profile controversial pro-trade rhino breeder is Dawie Groenewald. On the 19 June 2026, Dawie Groenewald, an ex-policeman, trophy hunter and rhino breeder, described by the National Prosecuting Authority of South Africa as the mastermind behind a large-scale rhino horn trafficking enterprise finally entered into a plea agreement with the State ending a legal saga of more than a decade in the Polokwane High Court.
The charges against Groenewald stem from a well-designed rhino horn trafficking enterprise emanating from incidents as far back as 2008. According to the indictment, Groenewald, in his capacity as manager of a professional hunting outfitter “Out of Africa” and by employing professional hunters and other individuals, managed the sourcing of rhino horns from his own rhinos and from other private rhino owners to fuel the black market in Southeast Asia.
Groenewald was sentenced to a fine of R2 million or four-years imprisonment, and a further 10 years’ imprisonment suspended for 5 years, with strict conditions on the main count of managing an enterprise (Contravention of Section 2(1)(f) of the Prevention of Organised Crime Act 121 of 1998).
Groenewald was further sentenced to high value fines and imprisonment on each of the other offences he was convicted on. The fines add up to more than R10 million and 36 years’ imprisonment. The sentences effectively restricted Groenewald for the next 5 years to act strictly in accordance with legislation relating to his rhino-related activities and or other restricted wildlife activities, or face a lengthy prison sentence if he does not comply with the strict conditions contained in the sentences imposed in terms of the plea and sentence agreement.
MINISTER AUCAMP’S EXCLUSIVE ENGAGEMENTS WITH WILDLIFE UTILISATION INTERESTS RAISE SERIOUS CONCERNS ABOUT BALANCE, BIAS AND TRANSPARENCY
The Wildlife Animal Protection Forum of South Africa (WAPFSA) notes with growing concern recent disclosures by Minister of Forestry, Fisheries and the Environment, Willie Aucamp, regarding his stakeholder engagements since assuming office.
The Minister’s Parliamentary response of 15 May 2026 reveals that he has held meetings with Wildlife Ranching South Africa (WRSA), the Professional Hunters’ Association of South Africa (PHASA), and the Professional Rhino Owners Association (PROA).
These organisations represent a particular segment of the wildlife sector: wildlife ranching, trophy hunting, private wildlife ownership and commercial wildlife utilisation interests.
Significantly, these organisations are associated with the broader sustainable-use and wildlife utilisation lobby and are linked through policy networks that have historically advanced positions aligned with SUCO-SA and its member organisations.
At the same time, there is no public indication that the Minister has undertaken equivalent engagements with animal welfare organisations, wildlife protection organisations, wildlife wellbeing advocates, animal law experts, humane conservation organisations, public-interest environmental groups, or communities concerned about the increasing commodification of wildlife.
This imbalance raises profound questions about whose voices are shaping South Africa’s wildlife policy.
A Question of Fair Representation
South Africa’s wildlife belongs to all South Africans.
Wildlife policy affects biodiversity conservation, animal welfare, wildlife wellbeing, rural communities, tourism, environmental justice, scientific research, public trust resources and South Africa’s international reputation.
No Minister entrusted with this responsibility should be perceived to be hearing predominantly from one side of a highly contested policy debate.
Yet the Minister’s own disclosures reveal precisely that.
The issue is not that the Minister has met with WRSA, PHASA or PROA.
The issue is that these are the only wildlife-sector organisations he has publicly identified as having met since taking office.
Importantly, the Minister’s first publicly disclosed wildlife-sector engagements were not with biodiversity scientists, conservation planning experts, animal welfare specialists, animal behaviour experts, community representatives or public-interest environmental organisations. They were with representatives of wildlife ranching, hunting and private wildlife ownership interests.
A Minister committed to balanced governance would be expected to engage broadly across the full spectrum of stakeholders, including those who challenge the assumptions and policy positions of the wildlife utilisation sector.
The absence of such engagement creates a reasonable perception that certain interests enjoy privileged access to decision-makers while others do not.
Misrepresenting the Concern
WAPFSA is also concerned by aspects of the Minister’s Parliamentary response that appear to mischaracterise the nature of the concerns being raised.
The Minister suggests that criticism arises from a failure to distinguish between captive wildlife industries and other forms of wildlife utilisation.
This is not the issue.
No serious observer disputes that captive breeding facilities, game ranches, hunting operations and private wildlife ownership structures are distinct categories.
The concern is that these sectors are interconnected politically, economically and institutionally, and frequently advocate common positions on matters relating to wildlife governance, wildlife ownership, trophy hunting, commercial breeding, intensive management practices and the broader sustainable-use agenda.
The Minister’s response therefore risks creating a false distinction that distracts from the central issue: whether South Africa’s wildlife policies are being informed by a sufficiently broad range of perspectives.
The answer, based on the Minister’s own disclosures, remains unclear.
The Perception of Bias Matters
WAPFSA acknowledges that no evidence has emerged of any unlawful conduct by the Minister.
However, public confidence in environmental governance depends on more than the absence of wrongdoing.
It requires transparency, independence and a demonstrable commitment to fair and balanced decision-making.
In his Parliamentary response, the Minister acknowledges that he holds an interest, through a family trust, in a game farm.
Public records further indicate that he remains a trustee of a family trust and has interests in a number of private companies.
WAPFSA is not suggesting that these interests automatically constitute a conflict of interest.
However, when such interests are considered alongside the Minister’s publicly expressed support for wildlife ranching and wildlife utilisation sectors, and when the Minister’s first disclosed stakeholder engagements are exclusively with organisations representing those same sectors, legitimate questions arise regarding the appearance of impartiality.
The standard expected of Cabinet Ministers is not merely the avoidance of actual conflicts of interest.
It is also the avoidance of circumstances that create a reasonable perception of bias.
That standard is particularly important where policy decisions affect public resources, biodiversity conservation, wildlife welfare and wildlife wellbeing.
Questions About Extractive Industry Interests Also Deserve Public Scrutiny
WAPFSA further notes that the Minister’s publicly declared interests include shareholdings and directorships in companies associated with mining contracting, mining solutions, aggregates, transport and related commercial activities. These interests are publicly recorded in Parliament’s Register of Members’ Interests.
WAPFSA makes no allegation of impropriety. Nor does WAPFSA suggest that individuals with business experience should be excluded from public office.
However, the Minister of Forestry, Fisheries and the Environment occupies a uniquely important position within South Africa’s environmental governance framework.
The Department is routinely required to make decisions affecting mining activities, biodiversity conservation, protected areas, environmental authorisations, environmental compliance and the balancing of economic development with ecological sustainability.
In these circumstances, transparency regarding actual, potential and perceived conflicts of interest is not merely desirable – it is essential.
The issue is not whether the Minister has complied with disclosure requirements.
The issue is whether sufficient safeguards exist to assure the public that environmental decision-making will remain independent, objective and free from undue influence from sectors whose commercial interests may, at times, come into tension with environmental protection objectives.
Public confidence in environmental governance depends upon the assurance that conservation, biodiversity protection and ecological integrity will never be subordinated to commercial interests, regardless of their source.
For this reason, WAPFSA believes that the Minister should proactively disclose how potential conflicts and perceived conflicts relating to wildlife utilisation interests, extractive industries and other commercial sectors will be identified and managed during his tenure.
The Minister’s Own Commitments Require Broader Engagement
According to his official profile published by the Department of Forestry, Fisheries and the Environment, Minister Aucamp presents himself as a leader committed to ensuring that governance remains connected to the realities faced by ordinary South Africans. The profile further emphasises balancing environmental stewardship with broader developmental concerns and recognises the responsible management of natural resources as a shared obligation.
WAPFSA welcomes these commitments.
However, these principles can only be realised through meaningful engagement with the full diversity of South African society.
If governance is genuinely to remain connected to the realities faced by ordinary South Africans, then stakeholder engagement cannot be limited primarily to organisations representing commercial wildlife utilisation interests.
If environmental stewardship is truly a shared responsibility, then wildlife policy discussions must also include organisations working on animal welfare, wildlife wellbeing, humane conservation, environmental justice, community rights, independent science and public-interest environmental protection.
The issue is not whether the Minister should meet with wildlife ranchers, hunting organisations and private wildlife owners.
He should.
The issue is whether he is meeting with everyone else as well.
The public record currently suggests a significant imbalance.
South Africans are entitled to expect that wildlife policy will be informed by a broad spectrum of perspectives and evidence, particularly on issues that remain deeply contested within society.
The Minister now has an opportunity to demonstrate, through his actions, the inclusive
leadership principles articulated in his own official profile.
Who Is Not Being Heard?
South Africans deserve to know why organisations representing wildlife utilisation interests appear to have secured early access to the Minister while organisations advocating animal welfare, wildlife wellbeing and humane conservation have not.
Where are the meetings with:
Animal welfare organisations?
Wildlife protection organisations?
Humane conservation practitioners?
Independent animal behaviour and welfare scientists?
Animal law scholars?
Public-interest environmental organisations?
Community groups affected by wildlife policies?
Indigenous knowledge holders whose perspectives may differ from commercial wildlife interests?
A healthy democracy requires all of these voices to be heard.
WAPFSA’s Call For Transparency
To restore confidence in the integrity and balance of wildlife governance, WAPFSA calls on Minister Aucamp to:
Publish a comprehensive register of all wildlife-sector stakeholder meetings held since assuming office.
Disclose all organisations and representatives who have been granted meetings with the Minister and senior departmental officials regarding wildlife policy matters.
Publish the criteria used to determine which stakeholders receive access to decision-makers.
Commit publicly to meeting organisations representing animal welfare, wildlife protection, wildlife wellbeing and humane conservation perspectives.
Establish a transparent and balanced stakeholder engagement framework that ensures no single interest group enjoys disproportionate influence over wildlife policy.
Make public the Department’s future programme of wildlife-sector consultations.
Demonstrate that future policy decisions will be informed by independent science, constitutional principles, transparency and the public interest rather than the preferences of a particular industry bloc.
South Africa Deserves Better
The future of wildlife governance in South Africa cannot be shaped primarily by those with direct economic interests in the commercial use of wildlife.
South Africans are increasingly demanding a more ethical, transparent and scientifically grounded approach to wildlife governance—one that recognises not only conservation outcomes, but also animal welfare, wildlife wellbeing, ecological integrity, democratic accountability and intergenerational justice.
The concern raised by WAPFSA is ultimately not about any single meeting, organisation or individual.
It is about whether South Africa’s environmental governance system is sufficiently independent, transparent and representative to command public confidence.
The Minister now has an opportunity to demonstrate that he serves all South Africans and not merely a narrow sector of the wildlife economy.
FORMAL DEMAND FOR ACCOUNTABILITY, TRANSPARENCY AND URGENT RESPONSE
The Wildlife Animal Protection Form South Africa (WAPFSA) has written to the Democratic Alliance Federal Council with escalating concern and deep frustration regarding their continued failure to acknowledge or respond to a formal complaintsubmitted on 10 November 2025.
More than four months have elapsed without even the courtesy of acknowledgement. This is not merely discourteous, it is a fundamental breach of the Democratic Alliance’s stated commitments to accountability, transparency, and constitutional governance.
This continued silence is unacceptable. It raises serious questions about whether the Democratic Alliance is willing or able to subject itself to the same standards of accountability that it demands of others.
This letter now serves not only as a renewed complaint, but as a formal escalation grounded in a materially worsened set of circumstances.
This matter is no longer simply about a failure to respond to correspondence. It concerns the integrity of governance, the protection of South Africa’s wildlife heritage and the ethical obligations of those in public office.
The response, or continued silence, will be taken as a clear indication of the Democratic Alliance’s position on these issues.
WAPFSA welcomes the opportunity to comment on the Draft Code of Conduct applicable to Environmental Management Inspectors (EMIs) and Environmental Mineral and Petroleum Inspectors (EMPIs).
WAPFSA acknowledges the importance of establishing clear professional, ethical and constitutional standards for inspectors tasked with environmental compliance and enforcement. The draft Code appropriately emphasises legality, integrity, accountability, transparency, environmental justice and protection of the public interest. These are essential pillars for an effective Environmental Management Inspectorate.
On Tuesday 3rd March 2026 WAPFSA addressed an open letter to Portfolio Committee on Forestry, Fisheries and the Environment
We write to you with deep concern regarding the apparent failure of the Department of Forestry, Fisheries and the Environment (DFFE) to give effect to its legislative and policy commitments in relation to wildlife well-being, specifically the operationalisation of the Wildlife Well-Being Forum (WWBF).
The Wildlife Animal Protection Forum of South Africa (WAPFSA) — a national network of 30 South African organisations — respectfully requests that the Portfolio Committee exercise its oversight function and investigate DFFE’s apparent lack of commitment to the Wildlife Well-Being Forum.
Meanwhile, DFFE continues to chair and participate regularly in the long-standing industry-focused Wildlife Forum which is composed exclusively of industry representatives and operates without civil society membership.This uneven engagement raises serious concerns regarding transparency, fairness, and balanced consultation.
In September 2025, South African Minister of Forestry, Fisheries and the Environment Dion George paused the CITES export quotas for elephants, rhinos and leopards due to ongoing legal challenges, sparking industry outrage over potential losses in revenue.
Dr Dion George was removed from his position in November 2025. Former Democratic Alliance National Spokesperson Mr Willie Aucamp was appointed as the new Minister of the Environment recommended by Democratic Alliance leader Mr John Steenhuisen despite concerns about a possible conflict of interest especially with regard to trophy hunting and game breeding.
It is incumbent on Minister Willie Aucamp to provide substantive and motivating reasons to permit the trophy hunting and export of TOPS listed species.
In the absence of such reasons, the decision to reinstate quotas for these species is susceptible to legal challenge on the grounds that it fails to give effect to the precautionary principle enshrined in section 2 of the National Environmental Management Act 107 of 1998 (NEMA), and is inconsistent with South Africa’s obligations under CITES to ensure that exports are not detrimental to the survival of the species.
The DFFE Gazetted Notice dated 6th February 2026 in our opinion, fails to include robust information on, among other things:
(a) how the trophy hunting of the three species fulfils the duty to protectthe environment in terms of Section 24 of the Constitution, read with section 2 of NEMA and section 57 of the National Environmental Management: Biodiversity Act 10 of 2004 (NEMBA);
(b) the rationale for selecting these three species for trophy hunting;
(c) how the quota quantities are determined and
(d) the distribution across the provinces;
(e) the economic benefits of trophy hunting in relation to the three species concerned, and precisely how the local communities will be benefitting;
(f) the welfare implications of the animal being hunted.
The inclusion of a definition of “well-being” in the NEMBA through the 2022 amendments has created a significant legal and ethical conflict with the trophy hunting industry in South Africa. The 2022 amendments to NEMBA define well-being as the holistic circumstances (physical, physiological, and mental health) that allow an animal to thrive.
WAPFSA argues that killing an animal for sport, often targeting prime, healthy, or endangered individuals, is inherently incompatible with the “holistic well-being” of that animal Where the DFFE authorised trophy hunting of TOPS-listed species, it must demonstrate how such authorisation is consistent with the well-being objectives embedded in NEMBA. No such justification has been provided in the GN of 6 February 2026.
WAPFSA members respectively request that its comments receive substantive consideration. We request that once the DFFE has reviewed all comments received, that a comments and responses table be made publicly available, evidencing the manner in which all Stakeholders’ comments were evaluated and analysed by the DFFE.
Green Group Simons Town interventions have demonstrated that behaviourally informed and holistic, non-aversive approaches, rooted in an understanding of baboon needs and movement, their foraging, and social dynamics, are essential for effective, ethical, and sustainable human–wildlife coexistence in natural environments on the edge of developed areas. These interventions, combined with robust waste management practices and public engagement, have proven successful in reducing conflict while maintaining the well-being of baboons and other wildlife. These results have been reported and published in a case study in 2025.
The Draft City Waste Management Strategy raises significant concerns. These include technical and cost inconsistencies, insufficient spatial coverage, procedural irregularities, failure to uphold duties of care, and lack of meaningful engagement with stakeholders.
This submission therefore provides a critique and proposes measures to ensure that the Waste Management Strategy is ecologically effective, legally defensible, and ethically sound.
The joint submission was made by WAPFSA Members Green Group Simonstown and the Southern African Faith Communities Environment Institute and supported by WAPFSA.
A Sword of Damocles: The Looming Threat of Permanent Removal of Chacma Baboons from the Cape Peninsula
Introduction
From the onset, more than thirty South African wildlife protection and conservation organisations have consistently opposed the Cape Peninsula Strategic Baboon Management Plan, which shockingly includes the deliberate extirpation of an indigenous species, the Chacma baboon species from Simon’s Town. Not only is the Plan unnecessary and cruel, crucially it fails to address, and indeed entrenches, insupportable human behaviour, which is the root cause of the negative baboon human interface.
An international wildlife organisation, Animal Survival International (ASI), has now entered the fray and sounded the alarm over the plans to permanently cage two Cape Peninsula baboon troops, highlighting obvious welfare and wellbeing issues and the potential permanent negative environmental impact.
This untenable situation has highlighted a deep divide between purposefully tone deaf authorities, aiming to cleanse certain suburbs of baboons, and conservationists pushing for coexistence, proper waste management and the protection of the baboons in their natural, though dwindling, habitat.
It is unfortunate, that the decision to remove and cage the baboons, and unnaturally and cruelly cast them into captivity for exhibition, has silenced some conservationists because they have been made to believe that if they oppose the permanent caging of the baboons, the baboons will be killed.
Cape Town – A City Deeply at Odds with Itself: Rapid Urban Development and Tourism versus the Protection of Biodiversity
Cape Town is located in an endangered ecosystem. The decision to permanently remove two entire baboon troops from Simon’s Town is contradictory to the content of the published Biodiversity Spatial Plan 2025 for Cape Town. The plan is striving to ensure that the City of Cape Town ecosystems remain intact. The intention of the Cape Town BioNet is to reduce conflict between environmental and developmental sectors by providing up-to-date information on biodiversity priorities that will guide forward planning, future development and conservation of nature.
The Western Cape’s biodiversity is threatened by tourism’s growing pressures which are leading to habitat loss, increased pollution, and strain on water resources. Tourism businesses in the Western Cape are being urged to prioritise biodiversity protection as visitor numbers continue to rise, placing growing pressure on the region’s natural systems.
The Cape Peninsula’s critical status as a global biodiversity hotspot, known as the Cape Floristic Region, and tourism’s growing recognition of the need for conservation, is sounding the alarm for the integration of sustainable practises into development and operations to protect the fragile ecosystems. In reality though, the rapid development for tourism infrastructure such as more accommodation, is encroaching on natural areas, fragmenting crucial habitats. Increased human activity is heightening risks to endangered plants and animals.
It is not only the growing tourism industry that is threatening biodiversity in the Western Cape, the City of Cape Town is actively pushing rapid development through major infrastructure projects, renewable energy initiatives housing plans, port expansion and economic strategies to boost tourism and jobs all guided by long-term plans like the Integrated Development Plan (IDP) and the Cape Town 2050 Long-term Plan.
The Atlantic Seaboard is experiencing a rapid high-density development boom, driven by intense investor interest, the post covid recovery of tourism and semigration. While this has fuelled record-breaking property sales it has simultaneously raised concerns about infrastructure strain, traffic congestion and loss of long-term rental affordability. Now there is increased urban and suburban development eroding the unique cultural, environmental and rural character of regions known as the Deep South on the Southern Peninsula of Cape Town. There are anxieties about unchecked modernisation and urban sprawl displacing local identity, green spaces and community character.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) contends that the Chacma baboon’s needs and natural behaviours are being disregarded in favour of trade and industry and rapid urban development. The Cape Peninsula Baboon Management Action Plan, agreed upon by the City of Cape Town led by the Democratic Alliance, SANParks and CapeNature, is a plan that aims to minimise human baboon interaction and keep baboons out of urban areas, primarily through measures such as permanent displacement and killing.
Their latest Action Plan includes capturing and relocating the Seaforth and Waterfall baboon troops from Simon’s Town to purpose built cages on private land on Plateau Road next door to the Cape Point Ostrich Farm. This facility will be open to paying tourists in order to sustain the costs involved with the permanent caging of the baboons.
CapeNature, one of the decisionmakers, is a conservation authority that formally aligns its policies with International Union for Conservation of Nature (IUCN) guidelines. Under the IUCN conflict-mitigation framework, the capture of a wild population and its placement into permanent captivity is not scientifically recognised or even quoted as a policy position.
It is also important to note that the Cape Peninsula Baboon Strategic Management Plan, made no reference to, nor made provision for, the capture and the permanent captivity of baboons. This proposal emerged later as part of the “final” Action Plan. This decision was published offering no scientific basis or reference to any public consultation.
The recently published 2025 Baboon Population Census commissioned by the Cape Baboon Partnership, a collaboration between Shark Spotters and the Cape Peninsula Baboon Management Joint Task Team comprising of the City of Cape Town, South African National Parks and CapeNature states that there are a total of 463 baboon individuals in the 12 managed troops on the Cape Peninsula. This number excludes the baboons living in the Cape Point section of Table Mountain National Park and the Plateau Road troop. This total number represents a 5.3% decline relative to the census carried out in 2024. Baboon conservation organisations have published their concerns, noting the high losses of troop members including the death of 101 baboons during this reporting period.
In the census document, the Seaforth troop, comprising of 16 individuals, is described as a troop that: “sleeps in surrounding mountainous areas but spends substantial portions of the day moving, through or attempting to access, the adjacent urban environment, bringing it into close proximity with residential areas and the critically endangered African penguin colony. This presents ongoing welfare and conservation challenges. In line with the Cape Peninsula Baboon Management Action Plan, a planned intervention will involve relocating the troop to a purpose built sanctuary to reduce the so-called conflict, limit ecological risk and improve welfare outcomes.”
The Waterfall troop, numbering 44 individuals, is described as: “spending a substantial proportion of its time in transformed environments, including regular use of urban areas in Simons Town, despite sustained ranger efforts to limit access. Under these conditions, the troop is exposed to elevated risk, relies heavily on anthropogenic food sources, and experiences ongoing disturbance. In line with the Action Plan, a planned management intervention will involve relocating the troop to a purpose-built sanctuary to address ongoing welfare and risk concerns for both baboons and residents.”
This forced, unnatural removal of baboons in order to “reduce conflict, limit ecological risk and improve welfare outcomes” is taking place in a national park and a UNESCO World Heritage Site, this cleansing of baboons is to be carried out by a city that markets itself globally as being abundantly ecologically diverse.
The permanent captivity plan for the baboons goes against their natural free-ranging existence. The plan also includes the sterilisation of male baboons which means that the baboons from Seaforth and Waterfall troops that survive the capture process will be the last surviving baboons from these historic troops. Tourists will be able to witness first-hand, what is, in our opinion, a failure of the Cape Peninsula Baboon Management Joint Task Team to protect, and sustain these baboons in their natural habitat.
Why are the Authorities Ignoring a Genuine Alternative?
Dr Dave Gaynor a Zoologist, a conservation ecologist, an expert in biodiversity, and wildlife management, has said that after a quarter of a century of baboon management, research and millions of rands spent, “we are going backwards.”
“Ecologically, losing baboons would be catastrophic for the Peninsula. Chacma baboons are not simply charismatic primates and a drawcard for tourists; they are a major seed disperser and ecosystem engineers within fynbos and move nutrients from low-lying areas to nutrient-poor high lying areas where they sleep. Studies and ecological assessments emphasise their role in dispersing seeds and potentially aiding germination, especially in post-fire landscapes where they forage on exposed seeds and early regrowth.
The baboons are part of the machinery that keeps this globally unique vegetation type functioning. Remove them, and you remove the resilience of the entire system. There is no neighbouring baboon population waiting to recolonise the southern Peninsula. Once they are gone, they are gone.”
WAPFSA questions why the detailed plans submitted by conservation organisations familiar with the baboons in Simon’s Town were never considered for discussion. These conservation organisations are most familiar with the baboon troop behaviour in Simons Town over decades, agree that partial fencing using tried and tested baboon fencing could be part of a solution that should be seriously and transparently considered.
This particular fencing is recognised by the Baboon Technical Team, animal welfare organisations and researchers at UCT’s Baboon Research Unit as a prototype for effective human-baboon overlap mitigation. Dr Gaynor has proposed an electrified baboon-proof fence along the existing firebreak above the town, bundled with the firebreak maintenance that is already required for safety.
Conservation organisations believe that the proposed fence line does not have to be continuous. They also believe that the natural wild areas for the baboons behind this fencing needs to be protected. This fenceline would make it possible for local baboon monitors and residents to prevent incursions without a small army field staff patrolling the mountain every day. It would confine baboons to their natural habitat while still allowing them to forage right up to the fence, which actually increases their effective home range by removing the constant need to be chased off the lower slopes. The fence is designed to safely allow unhindered access to mammals such as grey mongoose and genets and allow access to the mountain through gates at the trailhead, ensuring continued public access to the mountain. It would also protect the Boulders penguin colony by closing off the most used baboon and, most importantly, caracal’s access routes from the mountain into the coastal areas.
Conclusion
As long as anthropogenic attractants and unmanaged waste remain accessible, even a small number of baboons will enter areas to exploit those resources. Improving waste management and securing the safety and ecological integrity of the mountain in Simons Town are not optional measures; they are fundamental obligations under the existing management framework.
Experts have repeatedly warned that removing entire troops through killing or permanent captivity risks creating a genetic bottleneck within the remaining baboon populations. Both authorities and scientists have acknowledged this concern, yet no credible solution has been presented to address the long-term genetic consequences of removing a significant number of individuals from an already declining and geographically isolated population.
The Joint Task Team’s decision to capture the baboons (and kill those individuals who evade capture) and to permanently confine those who are captured, is in our opinion irrational and disproportionate. Such extreme measures are being pursued without implementing less invasive mitigation options explicitly identified in the management framework.
The excuse provided by the City of Cape Town is that they do not want to risk spending R6.5 million on a fence whose design they claim is unproven and which they fear might simply shift the baboons to other suburbs.
Dr Gaynor says that this reasoning is difficult to reconcile with the published evidence that baboon-proof fences of similar design have been successfully implemented in Zwaanswyk and other settings, and with SANParks own technical report acknowledging that such fences have been developed, refined and demonstrated in other parts of South Africa.
Yet the City of Cape Town is satisfied to risk spending in excess of R10 000 000 on building cages on private land. The annual costs needed to care for the caged baboons is considerable.
What is the real reason that the City of Cape Town wants the baboon permanently removed from Simons Town? Is the municipality planning further development in Simonstown? Is this why the City of Cape Town is reluctant to consider the alternative, more natural measures to discourage the baboons from entering the central business district? Is this an unwritten Democratic Alliance plan? To remove all inconvenient baboon species from the Cape Peninsula and the Overstrand?
Capetonians are apparently being forced to select a touted less harmful option between two undesirable choices, supposedly to choose the lesser of two evils. This suggests a dilemma where the only alternatives are captivity or death. This presents a false dichotomy, particularly because there are other robust and viable solutions besides caging or killing.
This framing relies on an unstated premise: that baboons must be permanently excluded from the south peninsula regardless of whether humans can reduce conflict drivers. But that premise is neither ethically neutral nor empirically established in the Action Plan narrative. If the real problem is attractants and predictable conflict points, then the relevant decision is not “cage or kill”, but which evidence-based, non-lethal coexistence measures will be implemented first, enforced consistently, and evaluated transparently. WAPFSA believes that the Cape Peninsula Baboon Management Joint Task Team may be deliberately misrepresenting the issue by presenting only two mutually exclusive options rather than the full, nuanced range of options. Importantly, a spectrum of possibilities exists.
Examples of realistic third options (and combinations of options) include:
Targeted spatial exclusion of food hotspots (protect specific high-risk edges rather than attempting permanent exclusion from entire suburbs).
Non-lethal behavioural management protocols that are internationally recognised and least-aversive, with independent monitoring and reporting.
Community coexistence requirements (baboon-proofing, waste compliance, and education as preconditions before any wildlife removal is justified).
Habitat/connectivity interventions that reduce forced urban crossings and bottlenecks.
This calculated oversimplification has led to flawed decision-making by fallaciously forcing a choice between two extremes. Simply put, the scenario is a constructed false dilemma scenario where the baboons presently living in Simonstown will be (i) captured and relocated to live out the remainder of their lives in cages and on display or (ii) they will all be killed.
The DA’s Action Plan for Baboon Management on the Cape Peninsula is a Grotesque Reminder of South Africa’s Terrible Past
PUBLIC STATEMENT
Members of the Wildlife Animal Protection Forum South Africa (WAPFSA) Primate Working Group, who are also representatives on the Cape Peninsula Baboon Advisory Group (CPBAG), walked out in protest during a Cape Peninsula Baboon Management meeting, held on Thursday, 20th November 2025.
The meeting was convened to announce the Action Plan, key actions, budget and timeframes for the future management of baboons on the Cape Peninsula.
The CPBAG, is a supposed stakeholder body, ostensibly established to advise the Cape Peninsula Baboon Management Joint Task Team (CPBMJTT) on the implementation of the Baboon Strategic Management Plan. Theoretically, the group facilitates communication between the CPBMJJ comprising representatives from SANParks, the City of Cape Town, and CapeNature, and communities, interest groups, and stakeholders to address human-baboon issues on the Cape Peninsula.
Communications addressed to the CPBAG from WAPFSA have never been acknowledged.
The Cape Peninsula is a global biodiversity hotspot. Nonetheless, there has been rapid development of urban areas and the expansion of the human footprint at great cost to the environment and driving significantbiodiversity loss and habitat fragmentation. Indigenous Chacma baboons on the Cape Peninsula have, consequently, lost vital food sources, foraging areas and traditional sleep sites and this has obviously led to more frequent human baboon interactions.
The goal of the CPBMJTT was to formulate a new strategy for the sustainable management of these baboons, supposedly for their long-term survival. On the 29 May 2025, the CPBMJTT announced a plan to remove several baboon troops from the Cape Peninsula due to increasing human conflict with baboons and limited natural foraging areas The task team stated that the health and welfare of baboons is compromised by their time spent in urban areas. The proposed actions included translocation to sanctuaries, the killing of baboons, or a combination of these options. The affected baboons were the Waterfall troop in Simon’s Town, the Seaforth troop in Simonstown, the CT1 troop in Constantia, the CT2 troop in Constantia and the Da Gama baboons in Glencairn.
On the 2 June 2025, thirty-four wildlife welfare organisations supported, the WAPFSA Cease and Desist Letteraddressed to the City of Cape Town, SANParks, CapeNature and Sharkspotters with regard to the proposal by the CPBMJTT to stop the removal of 121 baboons from the Cape Peninsula.
In the interim, the CPBMJTT has allegedly, robustly reviewed expert opinions and has widely considered public comments. The final decisions recorded in the Action Plan were inappropriately announced to the media before the CPBAG members had even been informed of these decisions on 20 November 2025.
WAPFSA’s Public Statement – The Cape Peninsula Baboon Management Joint Task Team (CPBMJTT) Action Plan:
Attention: Democratic Alliance Federal Legal Commission and Compliance
Monday 10th November 2025
OFFICIAL COMPLAINT: MINISTER STEENHUISEN PROPOSED NOMINEE TO REPLACE MINISTER DION GEORGE
Democratic Alliance leader and Minister of Agriculture John Steenhuisen has publicly proposed that Mr Willem Aucamp, National Spokesperson of the Democratic Alliance, replace Minister of Forestry, Fisheries and the Environment Dion George.
In our view, Mr Willem Aucamp’s private interests could influence the state’s decision-making to his own advantage, by shaping laws to benefit himself.
A Letter of Complaint to His Excellency President Cyril Ramaphosa
Monday 10th November 2025
Dear Mr President,
OFFICIAL COMPLAINT: MINISTER STEENHUISEN PROPOSED NOMINEE TO REPLACE MINISTER DION GEORGE
The Democratic Alliance leader and Minister of Agriculture John Steenhuisen has publicly proposed that Mr Willem Aucamp, National Spokesperson of the Democratic Alliance, replace Minister of Forestry, Fisheries and the Environment Dion George.
In our view, Mr Willem Aucamp’s private interests could influence the state’s decision-making to his own advantage, by shaping laws to benefit himself.
Please find a copy of the official WAPFSA complaint:
PROVINCIAL POLICIES ON BABOONS: THE SHOCKING CASE OF THE ABANDONED STORMBERG BABOONS
National and Provincial legislation, policies and attitudes towards indigenous primates are largely responsible for the persecution and extirpation of baboons in South Africa. They are trophy hunted, shot, poisoned, electrocuted on pylons, run over by vehicles, trapped for traditional medicine and bushmeat and killed by dogs. Many infants and juvenile baboons are orphaned when their mothers are killed. There is a dire need for educational sanctuaries and rehabilitation centres willing to take in orphaned and injured baboons and offer them protection and a life with their own kind either in natural habitat sanctuaries or back in the wild.
The establishment of the Stormberg Conservation Baboon Rehabilitation Centre and Sanctuary (NPC 2020/1148708) was officially permitted by the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) in the Eastern Cape. This so-called sanctuary dissolved without warning or notice in 2024 leaving thirty-nine Chacma baboons lives at risk on Klipfontein Farm, Witkop (near Burgersdorp).
Several non profit organisations, members of WAPFSA have been trying to assist these abandoned baboons. Primate C.A.R.E. agreed to help to manage the facility remotely with funding provided by the EMS Foundationto ensure that the rescued baboons were provided with food and other necessities and that staff employed at Klipfontein Farm who directly cared for the baboons were paid and provided with electricity. This emergency agreement came with the proviso that the baboons were allowed to remain safely in their enclosures on the farm owned by Theunis du Plessis for a period of twelve months or until a suitable new permanent sanctuary home could be established for them in the Eastern Cape. Karin Morgan agreed to oversee the day-to-day care of the baboons during this period and for that reason the provincial nature conservation permit was issued and registered in her name.
As a last resort, when no suitable rehabilitation facility could be determined in the Eastern Cape, the EMS Foundation offered to assist with the funding of the relocation of these thirty-nine baboons from the Eastern Cape to Primate C.A.R.E. in Limpopo Province. The EMS Foundation also agreed to fund the costs of constructing new enclosures for the baboons as well as provide funding towards their rehabilitation at Primate C.A.R.E.
DEDEAT agreed to provide permits for the thirty-nine baboons to be exported to Primate C.A.R.E. in Limpopo Province for rehabilitation and for them to be relocated back into the Eastern Cape for release by negotiated arrangement with private reserve owners. Of concern is the Eastern Cape authorities were not willing to provide these rehabilitated baboons an opportunity of release in any of their provincial reserves.
WAPFSA members have been reliably informed that orphaned baboons have been relocated from facilities who act as halfway houses for rescued primates, including baboons, in Eastern Cape Province to another primate sanctuary which is also based in Limpopo Province.
We Wild Africa a non-profit wildlife translocation logistical organisation agreed to provide the veterinary and logistical expertise for both the short-term and long-term planning for this emergency project. Primate C.A.R.E agreed to accept the thirty-nine baboons where each baboon will be individually assessed, and if need be, all thirty-nine baboons would be quarantined.
It is difficult to give an exact estimate of time that it will take to rehabilitate the baboons. Despite this fact, a reasonable timeframe has indeed been provided by Primate C.A.R.E one that has satisfied DEDEAT and therefore it should also be acceptable to the Limpopo Department of Economic Development, Environment and Tourism (LEDET).
WAPFSA is aware that the current permit held by Primate C.A.R.E stipulates that the import of baboons from other provinces are prohibited. However, the baboons are not going to remain in the Limpopo permanently they are going to be exported back to the Eastern Cape after they have been rehabilitated, i.e. this is a temporary arrangement. Moreover, WAPFSA questions the legality of refusal of baboons into Limpopo for sanctuary and rehabilitation.
Considering that there is a feasible solution for the thirty-nine baboons WAPFSA believes that LEDET should urgently consider the merits this extraordinary application which is supported by a number of wildlife conservation non-profit organisations and a provincial conservation agency in order to expedite a final decision/position on this matter. The parties concerned requested an urgent meeting between LEDET/EMS/CARE/DEDEA and the logistics and veterinarian experts. Unfortunately LEDET has refused this meeting.
Of critical importance is the fact that the owner of the farm in the Eastern Cape has requested that the baboons are removed as they no longer have a valid permit. According to DEDEA they are also suggesting that the thirty-nine baboons are killed within 72 hours.
“The landowner, may open the cages and chase the animals out and have a competent hunter dispatch the animals as humanly as possible. This option is the most cost effective for the landowner”
WAPFSA is hereby URGENTLY APPEALING to LEDET, particularly the Acting Director for Wildlife Trade and Regulation, Ms Paulina Moeng, to allow special permit conditions for this emergency situation.
WAPFSA has grave concerns about provincial authorities enabling the cruel, indiscriminate and unscientific management of vervet monkeys.
It has come to WAPFSA’s attention that some conservation agencies, including Ezemvelo KZN Wildlife, may be permitting the removal or even the eradication of individual or entire troops of indigenous non-human primates such as the vervet monkey.
A communication from Ezemvelo KZN Wildlife on the 10th October 2025 addressed to the Umdoni Retirement Community advises residents that Ezemvelo KZN Wildlife and the South African Police Services will be conducting a scheduled Wildlife Management Programme in the Umdoni.
WAPFSA questions whether permits have been issued without reliable scientific data and without adhering to best practices or carrying out sufficient due diligence, such as the assessment of the vervet monkeys or impacts on the overall populations of this species or targeted individuals affected.
Vervet monkeys are listed under CITES Appendix II, however provincial and national scientific authorities are failing to provide the Minister or CITES with the legally required Non-Detriment Finding. Moreover, there has been no public consultation by provincial and national authorities in relation to our indigenous primates.
There is no evidence, despite extensive research by members of WAPFSA, of verifiable data collected by any of the provinces in relation to damage or threats to humans or pets from vervet monkeys, or evidence of effective and non-violent measures to prevent human conflict with these primates.
In areas where there is the prospect for human-primate conflict, there are a number of simple precautions to take or solutions that can be implemented to reduce such conflict, such as, for example, making sure food is not visible from any windows, properly disposing of domestic waste and, if necessary, installing clear primate barriers. These simple strategies must be exhausted before considering any other option.
Often, in response to anecdotal reports or complaints linked to lifestyle considerations rather than real conflict, authorities have been known to issue very broad questionable permits to allow invasive and cruel management procedures instead of insisting upon non-lethal solutions.
Similarly, scientists advise that when vervet monkeys are killed, the removal of an entire or part of a troop is highly traumatic and cruel. Members of a large troop cannot be killed simultaneously which results in some of the troop members being traumatized. This impacts the entire troop.
DOWNLOAD WAPFSA COMMUNICATION SENT TO EZEMVELO KZN WILDLIFE:
Comments were submitted by environmental lawyers Cullinan and Associates to Nsovo Environmental Consulting on behalf of the landowners and entities which will be negatively affected by the proposed 131 km power line and substation works in Limpopo Province, South Africa.
“The Limpopo Province is characterised by exceptional biodiversity, offering both opportunities and constraints to development. Being so rich in natural resources – particularly in mineral deposits, agricultural potential, and eco-tourism assets – the province is well-positioned as a key contributor to South Africa’s economy. At the same time, these environmental assets are of national and global significance and therefore require careful management to ensure that development is sustainable and occurs within the ecological limits of the region.
Limpopo’s environmental landscape includes world-renowned conservation areas such as the Kruger National Park, numerous provincial and private nature reserves, two World Heritage Sites, two Ramsar wetlands, three Biosphere Reserves, two Transfrontier Conservation Areas, and several Important Bird Areas and Centres of Floristic Endemism. Collectively, these features form a network of ecosystems that underpin biodiversity, eco-tourism, and community livelihoods, and which contribute significantly to the province’s identity and sustainable development prospects.
Within this context, Foskor (Pty) Ltd operates as a major industrial actor in the province. Foskor is a South African company based in Phalaborwa, specialising in the extraction of phosphate rock, foskorite, and pyroxenite. The extracted phosphate rock is transported daily by rail to Foskor’s acid division in Richards Bay, KwaZulu-Natal, using a dedicated megaRAIL service for the production of phosphoric acid and fertiliser products. These products are primarily exported to international markets, with a smaller portion sold domestically. The proposed Merensky-Foskor 130 km powerline upgrade project has been presented as necessary to sustain and expand Foskor’s industrial operations.
The eco-tourism and conservation-based industries, which are prominent in this province, depend entirely on environments that are natural and that have been altered in only the most minimal way by human structures and activities. In this setting – where biodiversity conservation and sustainable land use are of central importance – any proposed infrastructure must be rigorously assessed to ensure that it does not erode the province’s ecological resilience, scenic integrity or long-term economic sustainability.
Amongst other, the 2025 Draft EIR has accordingly failed to give due consideration to the significance of our clients’ properties as an extension of the protected area complex surrounding the Kruger National Park, and the pristine status of the bushveld environment that will be negatively affected by the proposed powerline project. The consequence of this is that the 2025 Draft EIR has failed to identify and/or understated potentially significant impacts which the proposed powerline project will have for conservation efforts and related eco-tourism initiatives in the area. This failure to conduct a comprehensive, contextual assessment of the impacts on the receiving environment, before the environmental authorisation is granted, leaves significant gaps in understanding the full environmental consequences of the proposed project. This means that the 2025 Draft EIR will not enable a comprehensive consideration of all relevant factors by the competent authority to inform a rational and defensible decision. “
DOWNLOAD AND READ THE SUBMISSION MADE BY ENVIRONMENTAL LAWYERS CULLINAN AND ASSOCIATESON BEHALF OF WAPFSA AND OTHER AFFECTED PARTIES:
After yet more death, this time at the HERD elephant facility in Hoedspruit, WAPFSA has appealed to the Honourable Minister George, to facilitate an independent and public review of the captive elephant industry in South Africa with the view to the phasing out of the elephant facilities that offer unnatural interactions with humans.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national network of twenty-eight South African environmental and conservation organizations established in 2017 with a particular emphasis on wild animal protection expertise.
The Wildlife Animal Protection Forum of South Africa was invited to attend the Southern African Elephant Indaba which took place at Bonamanzi Game Reserve in Northern KwaZulu Natal in South Africa on the 12th and 13th August 2025.
The WAPFSA Southern African Elephant Indaba Report:
The Cape Peninsula and the Overstrand region of the Western Cape of South Africa are known for their significant UNESCO recognition. The Cape Floral Region Protected Areas is a designated UNESCO World Heritage Site, celebrated for its exception plant diversity and unique Fynbos vegetation. The Kogelberg Nature Reserve lies between Gordon’s Bay and Kleinmond in the Overstrand region of the Western Cape is considered a core conservation area.
The Cape Floral Region Protected Areas is a World Heritage Site inscribed in 2004 is located at the southwestern tip of South Africa and is one of the world’s major centers of terrestrial biodiversity. This region encompasses national parks, nature reserves, showcasing a remarkable array of endemic plant species particularly within the Fynbos vegetation. The site is managed by CapeNature and the Cape Action for People and the Environment programme.
The Cape Peninsula baboon population represents a genetically distinct peripheral population exhibiting unique behavioural adaptations to Mediterranean-type fynbos ecosystems. Each individual eliminated represents irreversible loss of evolutionary heritage shaped by millennia of adaptation to this UNESCO-recognised biodiversity hotspot and represents a unique evolutionary experiment in primate adaptation to Mediterranean-type ecosystems.
WAPFSA members share concern about the proposed removal of the chacma baboon from the Cape Peninsula and the Overstrand regions of the Western Cape of South Africa and the negative implications on the status of the UNESCO World Heritage Sites of the Cape Floral Kingdom.
Peninsula baboons serve as irreplaceable ecosystem engineers within the Cape Floral Kingdom, providing essential ecosystem services:
Seed Dispersal Networks: Long-distance dispersal of indigenous fynbos species, particularly large-seeded fynbos taxa, maintaining vegetation genetic diversity across fragmented landscapes through specialised gut passage and territorial movements spanning kilometres. Their daily foraging movements of 2-8 kilometres create critical dispersal networks connecting fragmented fynbos patches, facilitating gene flow in plant populations that co-evolved with primate-mediated dispersal over millennia.
Soil Nutrient Cycling: Foraging activities and strategic nutrient deposition significantly influence soil chemistry and plant community composition throughout 16 distinct territorial ranges.
Trophic Regulation: Complex predator-prey relationships with apex species whilst regulating invertebrate populations, maintaining ecological balance essential for fynbos ecosystem integrity. They also serve as prey for apex predators, maintaining critical predator-prey dynamics within the fynbos biome. Baboons also play roles in pollination facilitation and influence soil nutrient cycling.
The ecological implications of eliminating 25% of these dispersal agents extend far beyond baboon population dynamics. Endemic Protea species, many found nowhere else on Earth, depend on baboon seed vectors for long-distance dispersal between suitable habitat patches. Systematic reduction of dispersal agents fundamentally alters plant community composition, particularly critical following the December 2023 fires that already stressed regeneration capacity across the region. No efforts have been made to rehabilitate the area to improve foraging for the baboons.
WAPFSA Concern
WAPFSA is concerned about the negative consequences and the sustainability of the designated UNESCO World Heritage Sites of the Cape Floral Kingdom due to the aggressive management policies and or the permanent removal of the chacma baboons in these sensitive areas.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national network of twenty-eight South African environmental and conservation organizations established in 2017 with a particular emphasis on wild animal protection expertise.
WAPFSA is explicitly designed as a vehicle to engage with governments on the issue of the conservation, wellbeing and protection of wild animals and the natural environment in which they live.Our policy positions are based on robust science, ethical and compassionate conservation practices and harmonious co-existence within nature. WAPFSA’s activities are underpinned by an understanding that the inter-relationship between environmental protection, animal well-being, conservation and the values of dignity, compassion and humaneness are foundational to our constitutional democracy.
WAPFSA also advocates for the concepts of UBUNTU, the intrinsic value of wild animals and an integrative policy approach.
The WAPFSA non-human Primate Working Group has a particular interest in the management of chacma baboons inSouth Africa and has engaged with the Western Cape Provincial Government and with the Minister of Forestry, Fisheries and the Environment on several occasions. WAPFSA comments on the Cape Peninsula Baboon Strategic Management Plan are reflected and published on the SANParks website.
Members of WAPFSA are part of the Ministerial Wildlife Well-being Forum, instituted by the Department of Forestry,Fishery and the Environment (DFFE) in May 2023, by special request of former Minister Barbara Creecy, to consult organizations focused on best practices for the protection of wildlife, with the view to implement the provision of animal well-being in conservation practices. The Ministerial Wildlife Well-Being Forum Primate Task Team is chaired by a member of WAPFSA.
Baboons are complex agentic beings, analogous to humans. They have the capacity to suffer, share a common evolutionary and biological history, have their own unique cultures and form their own sovereign communities. Studies clearly show that other animals have rich inner lives, including languages and cultures, and recent work in political philosophy shows that they not only form their own communities, but often actively co-shape communities, habitats, and relations with humans.
When it comes to issues of management strategies, baboons warrant a very different approach from the one currently carried out by the CPBMJTT which: perpetuate settler coloniality; currently reflect a strictly utilitarian mindset – as seen from the application of lethal and pain aversion baboon management interventions and deliberately act to ‘invizibilize’ baboons.
Thirty-Four wildlife welfare organisations have supported the Cease and Desist Letter addressed to the City of Cape Town, SANParks, Cape Nature and Sharkspotters with regard the proposal by the CPBMJTT to remove baboons from the Cape Peninsula.
READ THE CEASE AND DESIST LETTER AND IMPORTANT APPENDIX:
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national network of thirty South African organizations established in 2017. WAPFSA is explicitly designed as a vehicle to engage with governments on the issue of the conservation, wellbeing and protection of wild animals and the natural environment in which they live.
Our policy positions are based on robust science, ethical and compassionate conservation practices and harmonious co-existence within nature.
On the 6 March 2025 WAPFSA sent a letter of concern to Dion George, the South African Minister of Environment Forestry and Fisheries, copying in other relevant sections in his department as well as the CITES Secretariat. The letter related to the export of a large number of wild animals among others leopards, cheetahs, lions and tigers from South Africa to the Greens Zoological Rescue and Rehabilitation Centre (GZRRC) in India (also known as Vantara).
Part of WAPFSA’s remit is the monitoring of international trade in wildlife. Bearing in mind that all South Africanshave a Constitutional right to have their environment protected through reasonable legislative and other measuresthat promote conservation as well as a right to the information held by the state that is required for the exercise of theenvironmental right, it is clearly reasonable and in the public interest that WAPFSA is permitted to raise concernsabout the international wildlife trade with the relevant authorities and ask them to investigate these concerns.
As is clear from the many links provided in our letter and Report, WAPFSA identified issues already publicly raised by others in published documents and sources and requested that the authorities investigate further. The tone of the letter is reasonable and respectful. WAPFSA addressed its concerns not to the media but to the properauthorities in South Africa.
On the 11th March 2025, WAPFSA received a letter from SHS Chambers, lawyers for the GZRRC, the content of which attempts to allege that WAPFSA’s letter to the South African organisation’s own government was defamatory and contained falsehoods.
Attorneys acting for WAPFSA responded to SHS Chambers on the 18th March 2025, stating that their allegations are both incorrect and unsubstantiated, furthermore they suggest that the real purpose of the letteris to intimidate WAPFSA into dropping its investigations, all of which are undertaken purely in the public interest,into wildlife trade from South Africa.
WAPFSA believes that for people to be able to participate fully in their country’s democratic systems and processes, they need information to help them make informed choices.
Where information is hidden, limited, or misconstrued to suit a certain agenda, people are excluded, unable to engage with governance issues from a well-rounded point of view and to hold their governments to account. This in turn impacts the realisation of human rights, not least because freedom of expression is itself a fundamental human right, constitutionally protected in South Africa and enshrined in Article 19 of the Universal Declaration of Human Rights.
Transparency and access to information, therefore, is non-negotiable, and it is what members of civil society organisations and the global media fight for, every day of their lives.
CONCERNS IN RELATION TO EXPORTS OF WILD ANIMALS TO INDIA
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national network of thirty South African organizations established in 2017. WAPFSA is explicitly designed as a vehicle to engage with governments on the issue of the conservation and protection of wild animals and the natural environment in which they live.
WAPFSA places the issues related to the conservation and protection of wild animals and the natural environment firmly onto the political agenda, our arguments are based on robust science, ethical and compassionate conservation practices and harmonious co-existence within nature.
The attached document highlights the concerning high number of leopard, cheetah, tigers and lions exported to GZZRC from South Africa.
Furthermore, we are of the opinion that a significant number of captive-bred specimens in facilities in South Africa could have been and are being traded for commercial purposes.
BABOONS NEED TO BE RESPECTED, NOT FEARED, HATED, HUNTED AND PERSECUTED BY CHILDREN AND ADULTS ALIKE IN SOUTH AFRICA
Wednesday 12th February 2025
The Members of WAPFSA are deeply concerned by reports of school children violently stoning and beating a dispersing male Chacma baboon, then according to reports, binding him with metal wire and a tire, and burning him to death, while at a school in Mpumalanga Province. This barbaric and inhumane act was captured on camera and shared on social media.
WAPFSA acknowledges the fact that South Africa is a violent country. According to the United National Office for Drugs and Crime, the South African murder rate for 2023 and 2024 of 45 per 100 000 is the second highest for countries that publish crime data.
Crime researchers use murder rate per 100 000 as a crude measure of the general level of violent interpersonal crime globally.
Witnessing such violence predicts and increase’s a child’s engagement in maladaptive behaviours, including the perpetration of violence towards humans and animals.
This particular act of violence towards a sentient and intelligent Chacma baboon needs to be thoroughly investigated and the consequences must be addressed without delay. Baboons are victims of inexplicable hatred in South Africa and are widely considered as vermin despite their complex social structure and intelligence.
Teaching Children that it is an Acceptable Practice to Shoot Baboons
Tens of millions of rands of taxpayers’ money has been spent on attempting to manage baboons in the Cape Peninsula and the Overstrand over the past two decades using protocols which, according the available data, and expert and public opinion, ignore baboon sentience and well-being and have not been successful for baboons or for humans.
For example, the Cape Peninsula Baboon-Strategic-Management-Plan sanctions the use of paintball markers against the 16 indigenous baboon troops historically present on the Peninsula as a management technique. Perhaps, encouraged by this violent management strategy, some residents have taken up arms such as pellet guns, and other lethal means, resulting in the death of numerous baboons this year.
Intensive research of these management practices in the Western Cape, has highlighted the fact that the protocols established to manage baboons were instituted by a baboon management company and adopted without a rigorous public participation process by the City of Cape Town Municipality, Cape Nature, SANParks and the Overstrand Municipality. These protocols must be recast. Baboon management, at the very least, requires a flexible, dynamic and compassionate approach.
In Pringle Bay in the Western Cape, the Overstrand Municipality has armed entire teams of individuals, employed via the extended Public Works Programme, with paint ball markers and other weapons to shoot the baboons out of the village. This violent approach ignores the fact that the Chacma baboon depends upon foraging areas within the village in order to survive.
There is evidence that this violent strategy in Pringle Bay has encouraged residents, including young adults to take up arms and to do the same with dire consequences for the welfare and wellbeing of the Chacma baboons.
Stop the Cycle of Anger and Violence
The witnessing violence may lead to the perpetration of further violence, will certainly involve desensitization, and decrease empathy. At the very least witnessing violence will result in maladaptive coping mechanisms and other learned behaviours.
The very public and barbaric killing of the Chacma baboon, fondly named Raygun by everyone who followed his journey through Pretoria, is an important alarm signal to bring in much needed change in our violent society. If we do not act now, and set an example, what hope is there for future generations of South Africans?
WAPFSA urges government institutions to reform outdated baboon management policies. Civil society and the public must recognise that we have reached a breaking point and take a firm stand against the persecution of baboons and the brutality they endure.
Image: Baboon shot in the face with a paintball marker in Pringle Bay
WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA STATEMENT ON THE EXPORT OF CHEETAH FROM SOUTH AFRICA TO INDA
According to a recent media article published by the Times of India, South Africa is apparently waiting quarterly progress reports on Project Cheetah, which are supposed to be sent by India’s Ministry of Environment, Forest and Climate Change as part of the MoU signed between the two countries. The project is stalled, according to an unnamed source, pending import permission from Convention on International Trade in Endangered Species Wild Fauna and Flora (CITES).
The seventy-eighth meeting of the CITES Standing Committee takes place in Geneva, Switzerland between the 3rd and 8th February 2025.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) welcomes the opportunity to support an investigation into current Cheetah export project between South Africa and India.
Until such transparent, robust investigation is concluded and published for comment, a moratorium should be placed on the future exports of wild Cheetah from South Africa to India. In addition, WAPFSA would welcome the assurance that Cheetah are not currently being captured and housed in bomas in South Africa for the next stage of the project.
“In November Minister of Forestry, Fisheries and the Environment, Dion George was officially asked if South Africa was intent on sending more Cheetah to India. He was also asked about the high mortality rate and significant problems that have been experienced in the recent export of Cheetah to India. The question was raised about why the project and the attendant export concerns were not included in the Cheetah non-detrimental findings.
Minister George responded by stating: “the Cheetah mortality rate in India had not exceeded the expected mortality and the mortalities experienced thus far, were withing the normal parameters for wild Cheetah reintroduction.”
A non-detrimental finding is about the impact of the export on the source population and not the suitability of the receiving country. Therefore, the NDF will not address the importing suitability but rather whether the export from South Africa is detrimental to the survival of the species in the wild in South Africa.”
Minister George, confirmed at the end of November 2024, that no additional Cheetah had been exported from South Africa to India. All application for exportation of additional Cheetah would be dealt with on a case by case basis and will also be informed by the periodic scientific assessments to be undertaken on the translocated Cheetah as well as the population viability analysis of Cheetahs in South Africa.
Concerns have, despite the Minister’s assurances, been raised by an international community of conservationists involved in the US$11 million project, who say inexperience and mismanagement as well as the government’s politization and the sideling of expert opinion may have contributed to the Cheetah deaths.
In addition, concerns for the vulnerability of the wild Cheetah species in South Africa have been addressed, with conservationists fearing that there does not seem to have been robust scientific research or planning carried out in India to support this project.
According to numerous media reports, a total of twenty Cheetah were exported to India from Namibia and South Africa. Currently, to the best of our knowledge, there are twenty-four Cheetah still alive, including the twelve cubs born in captivity in India.
It is important to note that all twenty-four Cheetahs are still in bomas (enclosures) ranging in size from 50 to 150 hectares in size.
After two years, all attempts to release the Cheetah from the bomas have been unsuccessful. The Cheetah that have been released have either died or have had to be recaptured after wandering away from the Kuno National Park in the central state of Madhya Pradesh. “
We act on behalf of the EMS Foundation (EMSF) (“our client”). Our client is a registered trust,nonprofit organisation and public benefit organisation, established in 2014. EMSF is committedto social and inclusive justice, compassion and the advancement and protection of the dignity,rights and general welfare of vulnerable and marginalised groups and individuals in South Africa,with particular focus on: youth at risk, the elderly and the conservation of wildlife.
2.This submission is made in response to the Notice published on 15 October 2024 by theDepartment of Forestry, Fisheries and the Environment, inviting public comment in the form of“written scientific information” on non-detriment findings (”NDFs”) for certain species (“theNDF Notice”).1
3.These comments are fully endorsed by the Wildlife Animal Protection Forum of South Africa(WAPFSA), a coalition of thirty diverse South African-based organisations united by sharedvalues and objectives. WAPFSA collectively comprise a body of expertise across variousdisciplines, including scientific research, environmental protection, legal advocacy, animalwelfare, human rights, social justice, climate action, indigenous knowledge, and public policy.Collectively, WAPFSA represents the interests of South Africa’s wildlife and naturalenvironment, working to engage government on issues such as biodiversity conservation,animal protection, ethical conservation practices, and the impacts of climate change.
4.While our client welcomes the publication of NDFs as a tool to fulfil South Africa’s obligationsunder the Convention on International Trade in Endangered Species of Wild Fauna and Flora(“CITES”), we submit that the Department’s current approach is procedurally, substantively andmethodologically deficient. Therefore, although the NDF Notice requires submissions in theform of “written scientific information,” our client bases its objections on broader legal,procedural and substantive issues. These submissions will therefore address:4.1. procedural flaws in the consultation process;
4.2. legal inadequacies in the development and implementation of NDFs under the NationalEnvironmental Management: Biodiversity Act, 2004 (“NEM:BA”);
4.3. methodological shortcomings in assessing species;
4.4. the lack of consideration of key legal principles, such as the precautionary approach; and
4.5. the failure to consider species well-being, as required under South African law.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) wishes to express our full support for the current Private Members Presentation Bill introduced by the Honourable Minister of Parliament David Reed.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national network of thirty South African organizations established in 2017 and which was explicitly designed as a vehicle to engage with government on wildlife issues and to put wild animals onto the political agenda, based on ethical and compassionate conservation and harmonious co-existence within nature.
Our members share clearly articulated principles that are part of our Founding Document. Our common goal is to safeguard and protect wild animals and their welfare and well-being, as well as biodiversity, individual species, individual animals and the interests of vulnerable people.
All our activities are underpinned by an understanding that the inter-relationship between environmental protection, animal well-being, conservation and the values of dignity, compassion and humaneness are foundational to our constitutional democracy, a position which has been recognized in South African jurisprudence We also advocate for the concepts of
UBUNTU, the intrinsic value of wild animals and an integrative policy approach, which requires the adoption of an attitude of respect to the individuals that make up a species, an eco-system or the components of biodiversity. Key to WAPFSA’s activities is the understanding that there is an urgent need to reimagine human-animal relations and that animal welfare and climate change are intertwined.
The undersigned organizations and community representatives, who are widely supported by wildlife conservationists across the African continent and beyond, would like to take this opportunity to share with you, our African perspective on the negative impacts of the commercialization, advertisement and sale of trophy hunts of African endangered and protected species.
WAPFSA hereby official submits our official objection to the Department of Forestry, Fisheries and the Environment’s invitation for written representations or objections to the Proposed Hunting/export quota for Elephant, Black Rhinoceros and Leopard Hunting Trophies for the 2024 and 2025 Calendar Year published as Notice Number: 5583 in the Government Gazette on the 22nd November 2024.
We note that this objection will be published and will be collated into a comment and responses report which will be made available to the public as part of the consultation process.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) is a national network of 30 South African organizations that was explicitly set up and designed as a vehicle to engage with government on wildlife issues and to put wild animals onto the political agenda, based on ethical and compassionate conservation and harmonious coexistence within nature.
WAPFSA members share clearly articulated principles that are part of our Founding Document, initiated in 2016. Our common goal is to safeguard and protect wild animals and their welfare and well-being, as well as biodiversity, individual species, individual animals and the interests of vulnerable people.
CITES: “Nationally established export quotas should as far as possible, be communicated at least 30 days before the start of the period to which the export relates”.
5. A calendar year is defined as the twelve-month period between January and December of any given year.
6. It is of great concern that a public consultation regarding the hunting/export of elephant, leopard and black rhino trophies for the 2024 Calendar Year has been initiated on the 22 day of the eleventh month of this 2024 calendar year.
7. This leaves 9 days of the 2024 calendar year remaining after the closure of the public consultation period, after which the Minister is required to give “due consideration” to the public representations received.
8. No explanation for this choice of timing has been provided. This timing is out of step with the CITES recommendations which provide that “nationally established export quotas should as far as possible, be communicated at least 30 days before the start of the period to which the export relates”.1
8. 1 Management of Nationally Determined Export Quotas, https://cites.org/eng/res/14/14-07R15.php
9. The publication of a quota for the 2024 calendar year so late in the year is in our opinion, unfair, unreasonable and irrational, and could be grounds for the setting aside of the current consultation process under section 6(2)(h). of PAJA.
Section 99 of NEMBA: “Public Participation Process sufficient information must be provided to enable members of the public to submit meaningful representations or objections”
10. As stated in the gazetted notice, the invitation for the submission of representations on the proposed 2024 and 2025 quota was issued in terms of sections 99 and 100 of NEMBA. These provisions set out the public consultation requirements for the Minister’s exercise of power under NEMBA.
11. Section 100(2)(b) sets out that notice of a public participation process under section 99 of NEMBA must contain “sufficient information to enable members of the public to submit meaningful representations or objections”.
12. The Gazetted Notice of consultation on the 2024 and 2025 proposed quota contains no quota figures.
13. In addition, because of the absence of the inclusion of the findings of the Scientific Authority and the rationale for the trophy hunting quota for black rhinoceros, leopard or elephant it is impossible for any member of the public to meaningfully interrogate or engage with the proposed 2024 or 2025 quota. This is both a material flaw in terms of section 100(2)(b) of NEMBA and under PAJA.
CITES Appendix I or Appendix II: Lack of Non-Detriment Findings
14. Further, the non-detrimental findings of the Scientific Authority, for the black rhinoceros, leopard of elephant are not even referred to nor provided in the Gazetted Notice.
15. These scientific findings should be confirmed as non-detrimental in relation to CITES Appendix I or Appendix II species which asserts that a restricted activity (such as trophy hunting and export) of these species will not be detrimental to the survival of the species in question.
16. Leopards and Black Rhinoceros are listed under CITES Appendix I while African Elephant populations in South Africa are listed under CITES Appendix II. All three species are also listed in the Lists of Threatened and Protected Species (TOPS) under the Threatened and Protected Species Regulations published in terms of section 56 of NEMBA (with leopards being listed as “vulnerable”; black rhinoceros as “endangered” and African Elephant as “protected”.
17. Section 62 of NEMBA refers to the publication of “Annual non-detrimental findings” which must be published in the Government Gazette allies to all three of these species. This is in line with the CITES recommendation that a “non-detriment finding should be made whenever an export quotas is established for the first time or revised, and reviewed annually.”
18. It is of material concern that hunting/export quotas for elephant, leopard and rhinoceros have been set in the absence of a current gazetted non-detriment finding in relation to these species in the current or preceding calendar year.
Conclusion: Procedurally unfair, unreasonable and irrational in terms of PAJA
19. Considering the points set out above, WAPFSA is of the opinion that this consultation process constitutes unlawful, procedurally unfair, unreasonable and irrational administrative action in terms of PAJA.
20. As the protection of South Africa’s wildlife is a matter of public interest, the Minister’s exercise of power quotas and initiating a flawed public consultation process constitute a breach of the South African public’s right to adequate public participation in matters that affect them, the right to just administrative action in of section 33 of the Constitution and the right to have the environment protected through legislative and other means in terms of section 24 of the Constitution.
21. The proposed quota and the consultation process should therefore be withdrawn. “
On Tuesday 19th November 2024, Cullinan and Associates, environment lawyers, acting on behalf of the Wildlife Animal Protection Forum of South Africa (WAPFSA), a collaborative network representing the interests of wild animals and the natural environment, which was established to engage government on animal protection, ethical and compassion conservation, welfare, biodiversity loss and climate change, among other issues, requested an extension period for written scientific information on non-detriment findings (NDFs) published on the 15th October 2024 by the Department of Forestry, Fisheries and the Environment.
“We refer to your Department’s Gazetted Notice calling for public comment in the form of “written scientific information” on non-detriment findings (NDFs) published on the 15th October 2024 “written scientific information” on non-detriment findings (NDFs) for certain species and“the NDF Notice”).
The NDF Notice requires comments tobe submitted by no later than 14 December 2024.
The NDF Notice asks for comments on more than 1000 species.
The purpose of this letter is to ask for an extension of the comment period until 16 February 2025.
All Members of the Wildlife Animal Protection Forum of South Africa were in support of this request.
FOR THE ATTENTION OFHIS EXCELLENCY, DUMA BOKO, PRESIDENT OF THE REPUBLIC OF BOTSWANA
19th November 2024
Dear Mr President Duma Boko,
A RESPECTFUL REQUEST TO RE-IMPOSE THE BAN ON ELEPHANT HUNTING IN BOTSWANA
The Wildlife Animal Protection Forum South Africa (WAPFSA) is a coalition of South African wildlife and environmental non-governmental organisations, please accept our warmest congratulations on your election as Botswana’s President. We hereby extend our best wishes for your success as you prepare to take up the responsibilities and challenges of this high office.
WAPFSA firmly believes that Botswana is one of the last places on earth where wildlife, especially elephants exist in significant numbers. Therefore, we believe that Botswana should be preserved as a non-trophy hunting area. As you embark on your new responsibilities WAPFSA humbly requests that you consider re-imposing the ban on elephant hunting in Botswana.
This ban would restore Botswana’s international reputation for conservation and in turn bolster revenue from tourism, the second largest source of foreign income after diamond mining. WAPFSA does not believe that by banning the trophy hunting of elephants that the levels of human elephant conflict will increase.
Instead, we believe that the world needs to find ways to make sure that communities living alongside this important, precious and iconic world heritage, benefit from photographic tourism and successful non-consumptive schemes, which link the conservation of wildlife and the natural ecosystems with sustainable improvements in their livelihoods.
Elephants, known for their intelligence, size and distinct appearance face a major threat from poaching an illegal practice driven by the demand for ivory and other elephant products. They remain the one of the most heavily poached mammals in the world, with a staggering 90% of African elephants being killed by poachers within the last 100 years.
WAPFSA remains concerned, particularly given that peer-reviewed data by experts points to a rise in thepoaching and killing of elephants for the trade in ivory, that the previous government of Botswana used aninflated figure (up to 237,000 elephants) to justify the need to consider unbanning trophy hunting and culling.
IUCN/PACO research shows that photographic safaris or eco-tourism creates 39 times more jobs than the trophy hunting for the equivalent surface area Photographic conservation tourism industry is the second largest revenue-generating industry to Botswana’s fiscus. If implemented these recommendations will do untold harm to the lucrative non-consumptive, eco-tourism sector in Botswana. They pose a direct threat to sustainable livelihoods in Botswana as well as to the country’s international reputation.
The following facts are also important to bear in mind:
1. A report published in October 2024 highlights a catastrophic 73% decline in the average size of global wildlife populations in just 50 years reveals a ‘system in peril’.
2. Given that we are in the midst of the Sixth Extinction and that elephant numbers are rapidly decreasing, the plights of elephants is of concern to all, and the efforts to ensure their future should be shared by all.
3. Elephants are extremely complex beings with physical, social and psychological interests who have intrinsic value and deserve respect.
4. Elephants are important to maintaining the ecological integrity of the region and thus we have locus standi in the matter.
5. The maintenance of regional ecological integrity is a pillar of our societal survival, ecologically, economically and socially.
6. Elephant migration routes are key in supporting ecological integrity and corridors for wildlife are vitally important for natural systems to exist and enable the movement of elephant populations out of Botswana.
7. South Africa had to abandon its elephant culling model because it was discredited from a scientific and a biodiversity management perspective
8. Botswana’ssupport for the ivory trade, via its proposal to the CITES Cop 18, fly in the face of the global momentum to reduce consumer demand for ivory and run counter to the recommendation in Resolution Conf.10.10. (Rev. CoP17) which calls for closure of domestic ivory markets contributing to poaching or illegal trade.
There is no compelling, empirical evidence of the economic significance of trophy hunting or that it is imperative to the future of conservation and to generate local community benefits. Moreover trophy hunting and culling are an added threat to wildlife.
In conclusion, WAPFSA firmly believes based upon irrefutable scientific evidence that trophy hunting and culling are not solutions to, nor will they mitigate, human- animal-conflict and will in fact result in increased conflict and added dangers to communities. Disrupting elephant social structures and hierarchies through trophy hunting and culling will further exacerbate human-elephant-conflict and also destroy social andecological knowledge and experience in the elephant societies.
The extent of human-elephant-conflict needs to be accurately ascertained and humane, innovative and collaborative solutions implemented in ways that benefit, and are a win- win for, communities and elephants (and other animals).
Signed by Members of the Wildlife Animal Protection Forum of South Africa
This memorandum of demands is addressed to: Honourable Minister Dion George, Honourable Minister Jon Steehuisen, Honourable Minister Anton Bredell, Honourable Minister Ivan Meyer, Honourable Deputy Mayor Eddie Andrews and Chairperson Dave Bryant
The Climate Justice Movement and the Co-Operative and Policy Alternative Center and the South African Food Sovereignty Campaign are calling upon Parliament to adopt the revised Food Sovereignty Act No. 1 of 2024 and Feed Ourselves Through Food Sovereignty Policy as comprehensive frameworks to address the systematic inequalities and climate vulnerabilities that threaten our communities.
WAPFSA stands united in calling for the immediate recognition of these demands, critical to ending hunger, thirst, and climate harm and protecting nature. The future of South Africa’s food system depends on a deep and triple-just transition that enters on the needs of people and the web of life. This is crucial as a cornerstone of the Climate Justice Charter and Climate Emergency Social Contract for all in South Africa. United we can give an emancipatory future to South Africa the planet and future generations.
The undersigned organisations are deeply concerned by the announcements by some governments in southern Africa to cull large numbers of elephants and other wild animals, including in National Parks.
In late August 2024, Namibia declared it would kill 723 wild animals, including 83 elephants and later increased this number to 100. Shortly afterwards, Zimbabwe announced its intention to kill at least 200 elephants.
The justifications given for these threats include a combination of providing meat to drought-stricken citizens, reducing pressure on land and water resources, mitigating human-elephant conflict, and reducing alleged wildlife over-population. However, while we acknowledge the severity of one of the worst droughts in decades in southern Africa, the killing of large numbers of wild animals cannot be justified for the reasons published in this statement:
WAPFSA members have expressed their concern about the possible importation of four hyenas into the George Water, Lion and Reptile Park located on the Garden Route region of the Western Cape of South Africa.
A few years ago, there was concern directed at CapeNature and questions were raised about the necessity of the opening of a wildlife park in George, a city in South Africa’s Western Cape, situated on a costal stretch known as the Garden Route. “South Africa has a great network of world-famous national parks protecting significant biodiversity and heritage and we should be encouraging people to visit these wilderness areas.”
Hyenas are intelligent animals and the nocturnal, secretive nature of hyenas presents unique challenges for exhibit in captivity. The complex social structure of hyenas dictates that these animals be housed in compatible groups. All hyenas should be provided with adequate space, ends and specific stimulation to prevent stereotypical behaviour.
The annual African Wildlife Consultative Forum (AWCF) is Safari Club International (SCI) premier activity in Africa.
The annual meeting, which is being facilitated by Stellenbosch University’s African Wildlife Economy Institute (AWEI) brings together professional hunting associations, hunting and conservation organisations, and range state government officials. The meeting will take place in Stellenbosch from 28 Oct – 1 Nov 2024.
Members of the Wildlife Animal Protection Forum of South Africa, have raised concern that Stellenbosch University is adopting a dangerous one sided approach to wildlife conservation.
READ the letter written to Stellenbosch University:
“I have seen at first-hand how injustice gets overlooked when the victims are powerless or vulnerable, when they have no one to speak up for them and no means of representing themselves… Animals are in precisely that position. Unless we are mindful of their interests, and speak out loudly on their behalf, abuse and cruelty goes unchallenged.” ARCHBISHOP DESMOND TUTU
7th October 2024
Congratulations on your appointment as Minister to the Department of Forestry, Fisheries and the Environment and to your first 100 days in Office.
On behalf of the members the Wildlife Animal Protection Forum of South Africa, I have enclosed a letter which contains issues of concern, which relevance and applicability are flagged for your consideration in relation to DFFE’s environmental policies with reference to wildlife:
Honourable Minister, WAPSA believes that addressing these nine issues of concern can significantly enhance the protection of South Africa’s precious biodiversity for generations to come.
WAPFSA has noted the motion by the SA Hunters and Game Association (SAHGCA) to strike down the legislation on the treatment of wild animals. Their complaint hinges on their claim that the State failed to facilitate sufficient public engagement in the crafting of the National Environmental Management Laws Amendment (Nemla) Act 2 of 2022.
They want certain provisions in the Act declared invalid and unconstitutional or suspended for a year pending more public discussion.
WAPFSA strongly believes in the merits of opposing this application.
The current Cooperative Agreement makes it very unlikely that this will happen, undermining transparency and accountability. The new Cooperative Agreement signed on 5 December 2018 creates legal framework for regulating trophy hunting in the Open System. However:
Directions of Parliament were not followed in the signing of the agreement.
Interested and affected parties were not invited to comment on the draft agreement.
SANParks persisted in signing it, despite the threat of legal action if it did so
No effective improvements in way trophy hunting is governed
Trophy hunting will continue to be governed by protocols adopted by the Joint Management Committee established by the agreement
Compliance with protocols is not mandatory
No penalties for not complying with the protocols
JMC has no legal personality (Is it a public body?)
Stakeholders who are not members of the JMC have no right to attend meetings
South Africa’s rhino horn stockpiles are driving the illegal trade in rhino horn. There have been numerous examples of rhino breeders and their industry colleagues who have been implicated in the illegal sale of hundreds of rhino horn, suspicious deaths of rhinos and in the possession of unmarked rhino horn.
South Africa’s pivotal role in the illegal international trade of rhino horn has been confirmed by numerous researchprojects and published in the South African Anti-Money Laundering Integrated Task Force Report.
Further reports presented at CITES CoP19 which harvested rhinos horns have been diverted from rhino horn stockpiles in South Arica to become a major source for the illegal wildlife trade.
A Report confirms that official South African rhino horn stockpile figures are conflicting, inconsistent untrustworthy and cannot be verified.
A volunteer based, registered non-profit organisation called Kogelberg Villages Environmental Trustees (KVET) whose mission it is to ensure the humane management of the Pringle Bay baboon troop and to prevent human-baboon conflict has publicly been accused of taming the Pringle Bay baboons.
A study carried out in Pringle Bay by a primatologist has confirmed that the Kogelberg Villages Environmental Trustees KVET BIOS were never witnessed attempting to influence the baboon troop movement in Pringle Bay. According to the report, the baboon’s movement in the village was minimally, if at all, influenced by the presence of either the KVET BIOS or the Overstrand Municipal baboon monitors.
The rhetoric expressed by some residents in Pringle Bay that KVET has negatively influenced the behaviour of the baboon troop in Pringle Bay is therefore false and deliberately misleading.
Analysed data, collected over a period of more than a year also indicates that there has been a reduction in the number of so-called house raids by the baboons who live in Pringle Bay in comparison to when the baboons were managed by a company contracted by the municipality called Human Wildlife Solutions.
Despite the condemnation of over three thousand participants and supporters of a petition, the human-baboon conflict in Pringle Bay is once again being addressed through short-term mitigation and incident preparedness measures, which includes the deployment of deterrents and or possible lethal control methods. Lethal because the shooting of baboons with paint ball markers is indiscriminate with no regard to lactating females and or infants and juveniles.
This approach, as we have learnt over time and past failed attempts, will only tackle the symptoms, but not the underlying causes. As an elephant ecologist once said, treating human-wildlife conflict with deterrents is akin to treating brain tumours only with Aspirin.
Wildfires, the reduction, fragmentation, and degradation of baboon habitat around Pringle Bay in the Western Cape of South Africa has meant that baboons are losing the space and the resources they need to survive. This has increased the visibility of the baboons in the village, which has for some residents developed into a competition between themselves and the baboons, a situation which is affecting the well-being of all. Some residents are reportedly experiencing negative impacts of a perceived quality of life which is directly eroding their tolerance of the conservation of the baboons which has led to the cruel deterrent control methods currently being deployed on the baboons Pringle Bay.
On Saturday 24th August, at 12 noon it was reported that Joey, the alpha male had been shot killed in Pringle Bay.
Joey’s death described as victim of violence, ignorance and intolerance. A large reward has been offered for information. An advocate and watching brief has been appointed to investigate the senseless killing.
The Cape Peninsula Baboon Management Joint Task Team (CPBMJTT) consisting of representatives from SANParks, CapeNature, and the City of Cape , called on communities from baboon-affected areas, stakeholders, and organisations from the South Peninsula with a direct interest in baboon management to nominate representatives to serve on the Cape Peninsula Baboon Advisory Group.
Formally constituted groups and organisations with a direct and special interest in the Southern Peninsula’s baboon population were encouraged to submit nominations. The closing date is 31st July 2024.
Members of the Wildlife Animal Protection Forum Nominated two member organisations:
On the 24th July 2024, this submission was made by the Wildlife Animal Protection Forum of South Africa (WAPFSA) in response to the draft Biodiversity Management Plan for Black Rhinoceros (Diceros Bicornis) and White Rhinoceros (Ceratotherium Simum) in South Africa published under Government Notice 4980 in Government Gazette 50829 of 18 June 2024.
WAPFSA was established as a vehicle to engage with government on wild life issues, and to put wild animals onto the political agenda based on ethical and compassionate conservation and harmonious coexistence within nature.
WAPFSA is a civil society network currently consisting of twenty eight (28) South African-based protection, conservation, environmental and community organisations that share certain common values, expertise and objectives.
WAPFSA’s activities are underpinned by an understanding that the inter-relationship between environmental protection, animal well-being, conservation and the values of dignity, compassion and humaneness are foundational to our constitutional democracy. WAPFSA also advocate for the concepts of UBUNTU, the intrinsic value of wild animals and an integrative policy approach.
Collectively, WAPFSA offers the South African government, a body of expertise from scientific, animal welfare, rights, social and climate justice, indigenous knowledge, public advocacy sectors and environmental law experts.
Given all the issues raised in this submission, WAPFSA’s recommendations are:
Close the domestic market for rhino horn by imposing a moratorium.
Conduct on-going mandatory audits of private and state-owned rhino horn stockpiles.
Strengthen and Improve law enforcement and operations to dismantle rhino horn trafficking syndicates.
Cooperate with all relevant and national foreign authorities.
Shut down all facilities that breed rhino for any purpose other than solely for conservation.
South Africa must abandon the idea of trading in rhino horn and encourage other Range States to do the same.
Rather than banking on the extinction of rhinos, South Africa must embrace rhino horn stockpile destruction as an anti-poaching, anti-trafficking, and demand reduction tool to meaningfully contribute to the ethical protection of rhino populations in Africa and Asia and to mitigate their extinction. Doing so will send a strong signal that South Africa is firmly committed to preserving and protecting rhinos, and to truly ensuring their welfare and well-being.
By virtue of the precautionary approach, South Africa, and other CITES States Parties must act in the best interest of the conservation of the species and urgently uplist rhinos currently on Appendix II to Appendix I.
EMS Foundation Address at the Four Paws State of Animal Welfare in South Africa Event
Michele Pickover, Executive Director of the EMS Foundation and founding member of WAPFSA delivered an address at WAPFSA close colleagues’, Four Paws South Africa, event in Cape Town on Friday evening 10th May 2024. The subject matter is extremely relevant considering that South Africans will be voting in the seventh democratic general election on the 29th May 2024.
“I cannot really talk about the Wildlife Animal Protection Forum of South Africa – WAPFSA for short – without referring to the historical context, because it has a lot to do with where WAPFSA is located and what we focus on.
In 1994, those of us that had been fighting the animal protection battle for years, were optimistic that our new democracy would also bring positive changes for non-human animals in South Africa – precisely because of the systemic commonalities which oppress both humans and nonhumans. Clearly, other animals were also victims of the systems of colonialism and apartheid. In essence, what we were advocating for – and still advocate for – is inclusive justice – one struggle – showing compassion across the species barrier and building a better future in a post-Apartheid South Africa.
As Archbishop Desmond Tutu observed – and I quote – “I have seen at first- hand how injustice gets overlooked when the victims are powerless or vulnerable, when they have no one to speak up for them and no means of representing themselves. Animals are in precisely that position. Unless we are mindful of their interests, and speak out loudly on their behalf, abuse and cruelty goes unchallenged.”
Other animals are sentient, conscious, feeling, and thinking beings; they have complex needs and relations; they have a will to live; and they play key roles in ecological systems necessary for our own existence. They have a life before they are traded, captured, enslaved, hunted and killed. They have agency. Indeed, they have their own cultures and traditions.
Nonetheless, they are conveniently kept in large amorphous groups and then disassembled and packaged in ways that reinforce the collective and conceal their individuality. They are viewed as a source of income, or as part of an aesthetically pleasing landscape, mere scenery – a backdrop to human activities. They are refigured, devoid of identities and, to all intents and purposes, almost invisible and imaginary.
If our non-human compatriots could speak our languages though, they would tell us they do not want to be our food, our trophies, our entertainment or our research tools.
After the death of apartheid, there was a window of opportunity for inclusive justice to be part of the process of building a new society and for the interests of non-human animals to be included in our new Constitution. Sadly, this never happened. And in relation to “wild animals,” there was no transformation of policies – but rather a seamless continuation – and in many ways a speeding up of existing exploitative practices and beneficiaries, including the so-called “wildlife industry”.
Historically, South Africa has always taken a pro-consumptive use stance in relation to wild animals. In the past it was so that a few people could benefit and have private hunting grounds. Now it is located within the language of development.
So, in a very real sense the South African government was – and still is – a formidable barrier to those fighting for justice for animals. In the wild life space, government was also only meeting with industry – via the Wildlife Forum – and, consequently, their agendas were driving government policies. Indeed, it is because the State was not taking any legislative responsibility that it has, to all intents and purposes, outsourced and devolved animal welfare issues to under-resourced animal welfare NGOs.
This is all particularly concerning because we are living in the Anthropocene Sixth Extinction Crisis. And humanity is the cause of this catastrophic collapse of nature’s ecosystems which is killing species and disrupting vast intricate webS of life. Currently there is an average 69% decline in wildpopulations globally. This is of existential importance.
Clearly, our fates are intertwined, and what we do to wild life, we do to ourselves. Because nature is in trouble, we are in trouble. Further massive losses in biodiversity can be prevented, BUT only through radical TRANSFORMATIVE change”. The world is speeding headlong toward disaster in flagrant disregard of science. And rhetoric, policy-making, and global agreements thus far have amounted to very little. A new moral compass, is desperately needed to guide and inform the institutional and conceptual changes necessary in this world.
So…..getting back to South Africa. There was no channel available for animal protection organisations to address their concerns to the government.
WAPFSA was therefore explicitly set up and designed as a vehicle to engage with the government on wild life issues and to put wild animals onto the political agenda, on the basis of ethical and compassionate conservation and harmonious coexistence within nature.
Our members share clearly articulated principles that are part of our Founding Document, initiated in 2016.
Our common goal is to safeguard and protect wild animals and their welfare and well-being, as well as biodiversity, individual species, individual animals and the interests of fragile people. All our activities are underpinned by an understanding that the inter-relationship between environmental protection, animal well-being, conservation and the values of dignity, compassion and humaneness are foundational to our constitutional democracy. We also advocate for the concepts of UBUNTU, the intrinsic value of wild animals and an integrative policy approach.
Also key to WAPFSA’s activities is the understanding that there is an urgent need to reimagine human-animal relations and that animal welfare and climate change are intertwined.
Currently there are 30 organisational members of WAPFSA – including other large networks and movements, for example The Climate Justice Charter Movement. The WAPFSA members span various areas of expertise, including: advocacy; education; Rights, Welfare, Conservation and Faith based approaches; species specialists; rescue and rehabilitation; legal and litigation; research; investigation; conflict mitigation and mediation; food sovereignty; community support and engagement; and indigenous knowledge.
Where there were previously silos, WAPFSA fosters collaboration, solidarity, unity, and action- to powerfully and collectively – lobby, campaign, mainstream and provide solutions to critical challenges and burning issues facing wild animals, nature and people in South Africa.
To conclude, WAPFSA’s strength lies in our unified approach to addressing these pressing issues from DIVERSE perspectives in an ethos of care and within the framework of inclusive social justice, so that our society can be transformed and so that we can all become good citizens of the BIO community. ALUTA CONTINUA AND THANK YOU.”
WAPFSA have sent an urgent letter to the Minister of Forestry, Fisheries and the Environment, Barbara Creecy with regard to the permit that was issued by LEDET to shoot to kill twenty baboons in the Blyde River Botanical Reserve in Limpopo Province. The permit is valid for one month and commences today, according to correspondence that we have received a hunter has been commissionedand he will be using a silencer.
WAPFSA addressed an urgent cease and desist letter to the Limpopo Department: Economic Development, Environment and Tourism today. Please download the letter:
The WAPFSA cease and desist letter sent this morning refers:
We have been advised that the permit to shoot and kill a troop of baboons in their natural range, has been issued by the LEDET. The culling exercise over the period of one month will be starting today 6th May 2024 at the Blyde River Botanical Reserve in the Limpopo Province. This permit has been apparently issued to reduce the baboons’ presence and so-called destructive nature, and a hunter has been appointed for the task.
We believe that it is the onus of the permitting authority to verify if the conditions to issue a permit exist and are legitimate, particularly when such issuing can have so grave consequences on the environment and the well-being of animals.
Please confirm that all procedures have been put in place and you have verified that:
a. There is effective proof of the so-called damage the baboons have caused. b. Methods used to discourage baboons from entering the residences in the aforementioned botanical reserve have been unsuccessfully applied; c. Photographic and video evidence of the destruction that these baboons have caused, have been provided to LEDET; d. Photographic evidence that baboon-proof measures and all mitigation procedures have been unsuccessfully put in place by the Reserve management, have been provided to LEDET before LEDET granted the permit.
Providing a permit to kill baboons because humans are inconvenienced is no legal basis upon which to issue such a permit. Kindly confirm the above.
The Wildlife Animal Protection Forum (WAPFSA), is a forum consisting of thirty South African organisations that are all actively involved with the protection and conservation of wild animals and the natural environment in South Africa. The members share a body of expertise from vastly different fields including, but not limited to, science, the environment, the law, animal welfare, human and non-human rights, social justice, the climate, the ocean, the indigenous perspective and public advocacy.
For the reasons expressed below in this document, WAPSA members firmly oppose the Adaptive Management Plan to move the Pringle Bay baboon troop out of the urban area, announced by the Overstrand Municipality on the 29th of April 2024.
In particular, WAPFSA opposes the reintroduction of weapons as a means to manage the baboons in Pringle Bay, because there are good reasons to believe that it will have a negative impact on the welfare of baboons and will not solve the problems.
WAPFSA proposes that the municipality adopt a different approach, focusing on tackling the factors drawing baboons into residential areas, as detailed further below.
In 2021 the residents of Pringle Bay highlighted the following points for change, these points are still applicable today:
No resident wants the baboons in their houses, but they also don’t want baboons constantly harassed, chased and shot at.
A shepherding approach needs to be followed by all monitors. The previous system used in Pringle Bay by the PBRA/PBBAG was an excellent method of managing the baboons. The monitors were polite and loved the baboons. They also notified residents by blowing whistles, clapping and ringing doorbells when thebaboons were in the area.
The infringement of private property needs to stop. Pringle Bay residents are tired of seeingbattles intheir gardens. Plots are crossed on foot by monitors, damaging sensitive fynbos.
Waste management needs to be addressed. Baboon-proof bins must be used by residents.The public bins scattered all over the Overstrand need to be fixed and maintained to prevent baboon access. Holidaymakers need to be made aware by rental agents and/or homeowners of the baboons. Homeowners also need to ensure any waste is disposed of in the correct way, e.g. taken to the dump, not left on the side of the road.
Signage at holiday homes, restaurants and shops must be erected. The message should be clear: no feeding of the baboons, no illegal dumping.
Newresidentsshouldbemadeawarebyestateagentsthattheyliveinabiosphereandithas animals that we need to protect. An information welcome pack should be provided to all new residents, and new builds and placed in the rental properties for the educational value it can provide regarding the presence of baboons in the area.
Houses must be baboon-proofed and access by baboons prevented. Special groups within the village should be set up to advise new residents on baboon proofing, etc. Building plan approval should be conditional on the inclusion of baboon proofing.
Shop owners in the central business district should display baboon information in their windows and have information pamphlets available to the public. Baboon-proofed bins and baboon safety doors should be requirements for all business owners.
Conclusion
WAPSA Members Oppose the Adaptive Management Plan to Move Pringle Bay Troop Out of the Urban Area Announced by the Overstrand Municipality on the 29th April 2024
WAPFSA hereby officially opposes the reintroduction of weapons as means to manage the baboons in Pringle Bay.
WAPFSA is hereby officially appealing for the immediate cessation of the anti-baboon rhetoric and the dangerous disinformation campaign that is being allowed to perpetuate on social media, which is fuelling the aggressive behaviour of some of the men in Pringle Bay.
KVET has conducted meetings with the South African Police Services and a criminal attorney and can confirm the activities that they are carrying out in Pringle Bay are not illegal. KVET is not collecting data on the residents of Pringle Bay, they are not hindering or obstructing the Overstrand Municipality employees in any manner whatsoever.
KVET is carrying out valuable community work in Pringle Bay at no cost to the Overstrand ratepayer.
A number of baboon experts, who have vast documented experience working with the Pringle Bay troop, have offered their learned opinions about the current baboon behaviour in Pringle Bay. A non-violent, transparent management strategy agreed upon by all stakeholders must be sought so that the troop can safely enter their sleep sites.
The Municipality should be encouraged to rebuild the waste dump site at no cost to the ratepayers and to make sure that residents baboon-proof their homes and the waste bins.
C.A.R.E. PRESENTATION ON WEDNESDAY 20TH MARCH 2024 TO THE MEMBERS OF THE WILDLIFE WELL-BEING FORUM
WAPFSA members Samantha Dewhirst and Stephen Munro from the Centre for Animal Rehabilitation and Education, C.A.R.E, invited the members of the Wildlife Wellbeing Forum to watch their presentation today. The objective of the presentation is to advise the Department of Forestry, Fisheries and the Environment and the Provincial Conservation Agencies, that there is a need to comply with the new provision of NEM:BA which now encompasses animal well-being. The presentation was also to encourage the increased protection of primates.
WAPFSA Members Agree and Request the Following from the Department of Forestry, Fisheries and the Environment:
All indigenous primates must be added to the TOPS list
Complex NDF’s are required for all indigenous primate species
Norms and Standards for all indigenous primate species need to be developed
A moratorium should be put in place until the NDF and N&S process, including transparent stakeholder consultation, is completed.
The Members of the Wildlife Animal Protection Forum of South Africa addressed an urgent letter to the Chief Executive Officer of the Mpumalanga Tourism and Parks Agency with regard to their concerns about permits issued by the MTPA which would enable the cruel, indiscriminate and unscientific management of vervet monkeys in Mpumalanga.
GRAVE CONCERNS ABOUT MPUMALANGA PROVINCIAL AUTHORITIES ENABLING THE CRUEL, INDISCRIMINATE AND UNSCIENTIFIC MANAGEMENT OF VERVET MONKEYS
The Wildlife Animal Protection Forum of South Africa (WAPFSA), a collective of thirty organisations, has a history of interest in the protection and conservation of wild animals in South Africa, sharing a body of expertise from different sectors including but not limited to scientific, environmental, legal, welfare, rights, social justice, climate, indigenous and public advocacy backgrounds.
Members of WAPFSA are also part of the Ministerial Wildlife Well-being Forum, instituted by the Department of Forestry, Fishery and the Environment (DFFE) in May 2023, by special request of Minister Barbara Creecy, in order to consult with organisations focused on best practices for the protection of wildlife.
The NEM:BA amendments came into effect on 30 June 2023. The Honourable Minister of Forestry, Fisheries and Environment, is currently in the process of implementing a legislative mandate to prohibit activities that may have a negative impact on the well-being of wild animals and to make regulations in relation to the well-being of wild animals, as per Section 2 of NEM:BA.
In the aforementioned section of NEM:BA, it is specified that all procedural activities that constitute biodiversity management, conservation and sustainable use of wild animals, including the issuing of permits, must consider the well-being of animals.
Section 9A of NEM:BA in particular, refers to any activity where there is reasonable evidence of a potential negative impact on animal well-being, using the wording “that may have a negative impact” which means that it is not required to have absolute proof of a negative impact to prohibit any activity. It implies that a precautionary approach, in line with the NEMA principles, must prevail.
WAPFSA members wrote a letter to the Minister of Forestry, Fisheries and the Environment on the 14th December 2023 requesting the inclusion six indigenous non-hum primate species in the South African Threatened or Protected Species Listing.
It is the Minister’s discretion to list species that fall into the criteria in Section 56 (1) (d): protected species. Such species do not necessarily have to be mentioned in other conservation lists such as the IUCN List or any other external lists. Provided that the proposed species fall into the description of those categories, they can be added to the TOPS list.
This followed the formal request from WAPFSA members on the 21st November 2023.
Despite new provisions in NEM:BA and a new vision of “secured, restored, and rewilded natural landscapes with thriving populations of Elephant, Lion, Rhino, and Leopard, as indicators for a vibrant, responsible, inclusive, transformed, and sustainable wildlife sector” this version of the TOPS Regulations remains focussed on the monetization of wildlife, including the endorsement of the continuation of certain activities such as commercial exhibitions, travelling exhibition of TOPS species, which include zoos and circuses and the continuation of the breeding, trading and exporting of TOPS.
In a reply from Minister Barbara Creecy to a letter from WAPFSA members Ban Animal Trading/EMS Foundation: “The legislative mandate to regulate the well-being of wild animals, which has been included in NEM:BA as an amendment through the National Environmental Management Laws Amendment Act, 2022 (Act No. 2 of 2022), came into force on 30 June 2023 when Proclamation Notice No. 125 was published in Government Gazette No. 48869. I now have the legislative mandate to prohibit activities that may have a negative impact on the well-being of wild animals, and to make regulations in relation to the well-being of wild animals. These legislative amendments will be initiated in due course.”
WAPFSA members have proposed the addition of non-human indigenous primates to the current TOPS list as protected species.
South Africa is home to six indigenous non-human primate species: the Chacma baboon, Samango monkey, Vervet monkey, Thick-tailed Bushbaby, Southern lesser Bushbaby, and Mozambique dwarfed Bushbaby.
WAPFSA Members strongly support the fact that non-human primates have high conservation value and national importance which require regulation in order to ensure that these species are managed in an ecologically sustainable manner and are protected in compliance with Section 24 of the Constitution.
The Wildlife Animal Protection Forum of South Africa WAPFSA is a collaborative network consisting of 30 (thirty) organisations representing the interests of wild animals and the natural environment as a vehicle with which to engage with the South African government on subject matter which includes, amongst other, wild animal protection, ethical and compassionate conservation, welfare, biodiversity loss and climate change.
South Africa is home to the world’s largest commercial lion farming industry. Lions are bred, often in appalling conditions, they are exploited for profit at every stage of their short lives.
At some facilities in South Africa cubs are removed from their mothers within a few days of their birth and are placed in the care of unsuspecting foreign and local volunteers who pay handsomely for the opportunity to look after “orphaned lions and other big cats”. Captive lions and other big cat cubs are also utilised in cub petting and various tourist interaction industries such as “walking with lions”.
When the cubs have reached the desired age and are no longer considered safe to be utilised in the tourist industry some of the lions are hunted for trophies either for the local hunting industry or for trophies that are exported to countries that condone canned lion hunting. Canned lion hunting reserves in South Africa typically have reinforced fences to prevent the lions from escaping during a hunt. Some of the lions are kept in small enclosures so that hunters with minimal skill, energy, patience or time can still successfully kill them.
The Members of WAPFSA are pleased that the Minister and the Department of Forestry, Fisheries and the Environment are finally initiating concrete steps against this distasteful industry. We encourage the South African government to do more to prevent the disturbing practices taking place at these breeding facilities.
WAPFSA members remain concerned about the trade, including live lions, the hunt and consumption of lions and all big cats and they stress the need for a just transition and re-establishment of harmonious coexistence with Nature and the protection of the web of life.
WAPFSA members support the acknowledgement of sentience in this Document and recommend that sentience is included and recognised in all DFFE policies and legislation in relation to wildlife. The inclusion of sentience is in line with the implementation of NEM:BA and the principles of wildlife well-being.
In the Draft prohibition, we noted the mention of the prohibition, of the introduction of live specimens of African lion; this therefore covers the prohibition of breeding and introducing new cubs. WAPFSA members are of the strong opinion that sentience should be referenced in this Prohibition and all the policies in relation to wildlife, underscoring the current efforts to implement principles of animal well-being as stated in NEM:BA and they stress that sentience should for no reason been removed in the finalised version of the document.
WAPFSA members would like the Draft Prohibition to properly address the issue of stockpiling, and implement the abolishment of all big cat bone stockpiles.
The prohibition to breed ALL big cats in South Africa is urgently required as currently there is a lack of effective monitoring and regulation at captive breeding facilities to monitor births, deaths transportation of live cats and the disposal of carcasses. This means that captive breeding facilities can act as a conduit for illegal and illicit trade. Similarly, prohibitions should be urgently promulgated to end the handling of, petting of and interactions with lions by humans for commercial purposes.
WAPFSA members support many elements contained in this Draft Policy Position, which are also in line with the White paper, these include:
“Thriving People and Nature”, which reconnects with Ubuntu, the Indigenous Knowledge and the principles of Harmonious Coexistence and is consistent with the United Nations Environment Program’s Living in Harmony with Nature by 2050;
“South Africa’s priority is to secure the survival of species in the wild”;
“Focus primarily on correcting unsustainable practices”;
“The environment is protected” as a priority;
“Duty of care” at the biodiversity, species and individual level
The well-being of wildlife is recognised, including the “well-being of individual animals”
“End the Captive keeping of Lion for commercial purposes” and
“Potentially apply this to other species”;
“Phasing out the domestication and intensification of management of Rhinoceros”.
WAPFSA members are, however, deeply concerned about the emphasis given to the set of human interactions that produce, trade, hunt and consume wildlife euphemistically known as the wildlife economy.
The White Paper on Conservation and Sustainable Use of South Africa`s Biodiversity (2022) although presenting the wildlife economy as an opportunity for growth, also indicates that the consumptive practices associated with it can have negative impacts if conducted too intensively, or inappropriately.
The Wildlife Animal Protection Forum South Africa (WAPFSA), consists of a community of diverse South African-based organisations who share similar values, knowledge and objectives. WAPFSA collectively offers a formidable body of expertise and advocacy drawn from different sectors, including but not limited to, scientific, environmental, legal, welfare, rights, social justice and indigenous knowledge.
Member organisations of the Wildlife Animal Protection Forum of South Africa have written an open letter to Minister Barbara Creecy, amongst others, highlighting their concerns about an elephant hunt which took place in Balule Nature Reserve, in Limpopo Province of South Africa on the 3rd September 2023.
The Balule Nature Reserve forms part of the Associated Private Nature Reserves, (APNR), an association of privately owned nature reserves bordering the Kruger National Park (KNP). The fences were dropped in 1993 – before the end of apartheid – on the premise of creating ‘ecological unity’ between the APNR and the KNP itself. Commercial hunting, in the 1996 agreement, was not mentioned at all. Animals under public custodianship (KNP) now move freely between the APNR and the KNP. Far from creating ecological unity, however, they are treated as res nullius (nobody’s property) in the APNR and are hunted. South African National Parks (SANParks) has never addressed this problem.
The elephant bulls that are commercially trophy hunted in the Balule Nature Reserve form part of South Africa’s national heritage but they are being killed for the benefit of a small number of wealthy white landowners as the amount of money actually accruing to local communities remains unknown.
On Sunday the 3rd of September 2023, a bull elephant was shot and wounded by a trophy hunter in the Maseke area of the Balule Nature Reserve. Obviously, the traumatised and injured elephant attempted to get away. He left the Maseke area and went into the neighbouring Grietjie Private Nature Reserve. The deputy head warden of Maseke initiated a search for the elephant with a helicopter. The elephant was located and driven back to Maseke using the helicopter where he was killed.
According to Mr Ian Novak the General Manager of Balule Nature Reserve, the elephant hunt was legal and no Greater Limpopo Transfrontier Conservation Area Reserve Protocol violations were committed.
Maseke is a region located within the Balule Nature Reserve. Maseke Game Reserve, Balule Nature Reserve and Grietjie Nature Reserve all form part of the Greater Limpopo Transfrontier Conservation Area Reserve.
The Greater Kruger Hunting Protocol was developed and endorsed by signatories which included representatives from South African National Parks, Limpopo Economic Development, Environment and Tourism and Mpumalanga Tourism and Parks Agencies. The number of elephants that are allowed to be hunted annually is determined by the Associated Private Nature Reserves ecological panel and reviewed and then endorsed by SANParks and the Limpopo Economic Development, Environment and Tourism Biodiversity.
Many international visitors to South Africa, and to the Kruger National Park, are unaware that the hunting of elephants is permissible. The Kruger National Park was named as one of the World Wonders on the new list which was published on the 14th of September 2023. “A listing that reveals global landmarks and natural marvels that the world is most curious about.” The Kruger National Park forms part of the UNESCO Kruger to Canyon Biosphere Reserve.
The fences separating all the Associated Private Nature Reserves and the Kruger National Park were dropped to reduce fragmentation, facilitate migration and increase space for wildlife and access to resources, in other words, to increase the well-being of animals. The perennial Olifants River flows for approximately 20 km through the centre of the Balule reserve and, for example, elephants cross Maseke into Grietjie to access the river.
The killing of this particular elephant was described as being upsetting to some and not an ideal situation. Of major concern is that this is not the first time that there has been a controversial elephant hunt on Maseke. On the 23rd November 2018, Sharon Haussmann, the then chairperson of Balule, initiated a full investigation after an elephant was shot thirteen times in front of guests. Sharon Haussman described that incident as completely unethical, inconsiderate and a huge embarrassment for Balule.
In the APNR, current and historical mismanagement, breaches of the Greater Kruger Hunting Protocols, and sometimes even negligence during trophy hunts, reflect not only badly on the hunting fraternity, but also on the photographic safari or eco-tourism sector in the Greater Kruger National Park and South Africa as a whole. Some examples include:
Early 2005, an elephant hunted in the Klaserie was shot 21 times before it succumbed.
In June 2005, an American hunter wounded an elephant in Balule, but only killed it 24 hours later.
In March 2006, a lion, one of a well-known pair known as the “Sohebele brothers” was shot and wounded in the Umbabat, but the hunter was unable to kill the animal, as its brother refused to leave the scene. The hunter later repeatedly drove a tractor at the lions in an attempt to separate them but failed. The lion was killed by rangers only the following morning.
Later that month, a large, one-tusked male elephant was shot and wounded by a Spanish hunter in the Umbabat, believed to have fled into the KNP and was not found since.
March 2013, an elephant was shot in the very close proximity to Ingwelala’s eastern boundary. The wounded elephantl ran directly south towards Motswari Lodge and was followed by the hunting party, who continued to fire 20+ shots before it was finally killed in the close proximity to the lodge with many guests. Motswari Lodge was never informed that this hunt was to take place and was caught completely off-guard. The effect on their guests and staff was devastating.
In August 2018, a scheduled elephant hunt conducted in Balule led to the illegal killing of a collared male elephant. Mpumalanga Tourism and Parks Authority (MTPA) laid criminal charges and the warden was subsequently convicted.
In December 2018, a young elephant was shot multiple times in Balule in front of photographic safari tourists staying at a neighbouring property.
After the latest unfortunate hunting incident, the General Manager of Balule stated that: “Hunting is never an exact science and no matter how many targets a client shoots at before the hunt, there is never any guarantee that he will make the perfect shot when faced with the real thing. The nature of a hunt is unpredictable and this is not a reflection on the capabilities of the Maseke Reserve Representative.
WAPFSA is ethically opposed to the hunting and killing of any animal for sport or pleasure. WAPFSA has openly challenged claims made by proponents of trophy hunting that it delivers significant conservation and community benefits or that it positively contributes to the sustainable use of wildlife in South Africa.
WAPFSA has previously highlighted how trophy hunting is rooted in colonial modes of extraction which continues to perpetuate notions of abuse, subjugation, control and inequality. Dr Muchazondida Mkono’s research[1] has found that trophy hunting is an objectionable consequence of a complex historical and postcolonial association. Africans have a deep resentment towards what is viewed as the neo-colonial character of trophy hunting, in the way it privileges Western elites in accessing Africa’s wildlife.
WAPFSA also opposes trophy hunting based on scientific evidence. In relation to elephants, research challenges the assumptions by trophy hunters that selectively killing older male elephants has no negative consequences because they are “redundant” in the population. Elephants are sentient beings who live socially complex lives through relationships which radiate out from a mother-offspring bond through families, clans, and sub populations. Independent males form long-term friendships. Elephants communicate through more than 300 gestures, complex speech and glandular secretions. They contemplate, negotiate, collaborate, plan and are aware of death. They care about their lives. The killing of older males has a detrimental effect on the wider elephant society through loss of leaders crucial to younger male navigation. In addition, when trophy hunters eliminate these older bulls, they destroy elephant family integrity (through trauma and removal of the discipline and knowledge transfer functions executed by patriarchs) and force matriarchs to mate with younger bulls they would otherwise not have selected, thereby skewing reproduction patterns.
According to the General Manager of the Balule Nature Reserve, Maseke is permitted to kill twelve elephants per year, a practise which he states will continue, and one which is, in their opinion, in line with the constitution of South Africa.
However, in terms of NEM:BA, the South African government is entitled to make policy decisions in relation to contentious and damaging practices, decisions that are in the public interest, prioritising public opinion and the economic benefits of the public.
NEM:BA includes the notion of “well-being”, which is defined as the “holistic circumstances and conditions of an animal, which are conducive to its physical, physiological and mental health and quality of life, including the ability to cope with its environment.” The consideration of the well-being of animals must be included in the management, conservation and sustainable use thereof”.
The entirely new section, 9A in NEM:BA, empowers the DFFE Minister to prohibit certain activities “that may negatively impact on the well-being of an animal […]” and create new offences “relating to non-compliance with s9A”; S101, then, refers to accountability of “person who contravenes or fails to comply […]”
It is our considered view that well-being falls within DFFE and the Minister’s legal mandate. The amendment to section 2 makes it necessary for well-being to be specifically considered, including when permits are granted, including those for hunting and all decisions that constitute “management, conservation and sustainable use” of animals.
S9A is widely drafted and applies to any activity, including hunting, as well as any other activities not so defined, provided there was reasonable evidence of a potential negative impact on wellbeing. S9A also uses the wording “that may have a negative impact” which means that the Minister is not required to provide absolute proof of a negative impact before making a prohibition.
Given the above amendments to NEM:BA, it is competent for the Honourable Minister to:
Prohibit specific activities involving animals under s9A on the basis that there is already evidence that the activities impact negatively on wellbeing; and/or
Publish a notice under section 9A prohibiting specific activities if there is reasonable evidence to support the view that this may have a negative effect on well-being;
Make regulations relating to the well-being of animals under s97; and/or
Challenge decisions of conservation officials which constitute administrative action (such as permitting decisions or the setting of quotas) on the basis that well-being is a relevant factor and has not been considered or on the basis that the decision would have a negative impact on the well-being of an animal or animals.
The aforementioned letter from the General Manager of Balule concluded that the hunt was conducted in accordance with the requirements and approved protocols. Have the representatives from South African National Parks, Limpopo Economic Development, Environment and Tourism and Mpumalanga Tourism and Parks Agencies taken the amendments to NEM:BA into consideration, are their approved protocols compliant with the national legislation and particularly with the duty of taking into account the well-being of animals in any hunt?
WAPFSA is aware that there is an ongoing court case, which seeks to challenge hunting and export quotas permitted by the government, in the Western Cape High Court. In light of this legal challenge, the undesigning members of WAPFSA are requesting Minister Creecy to:
Investigate if permits to hunt twelve elephants were issued, as specified in the letter from the Balule administration, despite the interim interdict.
Revoke permits and halt any further hunt of elephants as well as rhinos, leopards and lions as per interdict,
AS this is not the first incident, withhold hunting permits to the Maseke-based hunting entity involved; and
Finally address the complex issue of trophy hunting as it is allowed in certain unfenced reserves of the APNR and elsewhere, and is incompatible with individual animal and species’ well-being considerations.
[1] Mucha Mkono (2019) Neo-colonialism and greed: Africans’ views on trophy hunting in social media, Journal of Sustainable Tourism, 27:5, 689-704, DOI: 10.1080/09669582.2019.1604719
Image Credit: EMS Foundation, an elephant in the Kruger National Park February 2023
“It has come to the attention of WAPFSA that Wildlife Ranching South Africa (WRSA) has included WAPFSA on the Forum and Membership menu of their website, and in addition, mistakenly used the South African Department of Forestry, Fisheries and Environment logo.
WAPFSA has requested that WRSA urgently removes WAPFSA from the WRSA website.”
On the 3rd September 2023 WAPFSA formally objected to the construction of a Eskom Foskor-Merensky 400kV power line and the associated sustain works in the Mopane and Sekhukhune district municipalities on the grounds that this project will have disastrous negative consequences for wildlife conservation in an important wildlife corridor and sensitive biodiversity area.
The proposed power line project stands in stark contrast to the principles and goals enshrined in the recently approved White Paper on Conservation and Sustainable Use of South Africa’s Biodiversity (the ‘White Paper’).
In light of the objections listed WAPFSA is of the view that the DSR requires significant revision, including consultation with environmental experts before the process can be allowed to continue.
The Wildlife Animal Protection Forum of South Africa (WAPFSA) wishes to express our deep concern that time is running out for the Hunting Trophies (Import Prohibition) Bill, which carries overwhelming public support and would fulfil a government manifesto commitment, to become law.
The Bill’s Committee Stage in the House of Lords has yet to be scheduled, and with the current parliamentary session due to end in November, there is a real danger that the Bill will run out of time. Lords Hamilton and Mancroft have also tabled amendments which would fatally weaken the Bill.
WAPFSA is a community of diverse South African-based organisations that share certain values, knowledge and objectives and that collectively comprise a body of expertise from different sectors including but not limited to scientific, environmental, legal, welfare, rights, social justice, indigenous and public advocacy backgrounds.
The undersigned organisations and community representatives are widely supported by wildlife conservationists across the African continent and beyond and would like to take this opportunity to share our African perspective on the negative impacts of the commercialisation, advertisement and sale of trophy hunts of African endangered and protected species with you.
Countries across Europe have acknowledged the fact that trophy hunting has little connection with conservation, on the 13th of December 2022 the Finnish Parliament approved a new nature conservation law that includes the banning of imports of hunting trophies from endangered species.
The Finnish Nature Conservation Act will enter into force on the 1st of June 2023. In 2015 France specifically banned the import of lion trophies. In 2016 the Netherlands banned the import of hunting trophies of over 200 hundred species. In March 2022 the Belgium Parliament adopted a resolution urging the government to immediately end the authorisation of trophy import permits for certain threatened and endangered species.
Scientists tell us that removing male mammals from their populations can increase the risks of species extinction. By selecting the most impressive, largest, most rare, usually male, that is usually the strongest and fittest in order to become the best trophy (largest tusks and thickest manes), trophy hunters affect reproductivity thereby weakening populations’ genetic health and variation, dislocating the surviving members of the group’s social structure, disrupting bonds and behaviours.
“Hunting Africa, Trophy Hunting, Neo-colonialism and Land” is an investigative report written by Professor Sian Sullivan, in which she confirms Safari Club International World Hunting Award Field Journal dedicates more pages to Africa than any other continent. “These figures clearly show the dependence of the trophy hunting industry on securing access to Africa’s hunting grounds. Given that the hunting industry claims to African lands requires removal of African peoples and constraints on local production practices, it arguably promotes and extends colonial patterns of enclosure.”
Trophy hunting is rooted in colonial modes of extraction that perpetuate notions of abuse, subjugation, control and inequality, including gender inequality Dr Muchazondida Mkono’s research[1] has found that trophy hunting is an objectionable consequence of a complex historical and postcolonial association. Africans have a deep resentment towards what is viewed as the neo-colonial character of trophy hunting, in the way it privileges Western elites in accessing Africa’s wildlife.
Proponents of trophy hunting argue that trophy hunting provides vast economic opportunities for local communities whereas, in truth, the economic benefits of big game hunting are wildly exaggerated and pale in comparison to the economic possibilities of eco-tourism. Yet, according to a 2013 study by Economists at Large, only 3% of the revenue generated by trophy hunting remains with local communities in Africa. In addition, hunting quotas are often set according to economic interests and market demand rather than population abundance and are not based on scientific data or standards.
In reality, trophy hunting is an elitist hobby for millionaires and billionaires who pay huge fees to kill large exotic and rare animals. Cash-strapped and corrupt governments in developing countries allow the colonialist sport to continue. According to a Report by Good Governance Africa, compared with tourism, trophy hunting provides very little benefit. The Report also questions whether the legally sanctioned killing of wild animals can be reasonably tolerated.
When there is a conflict between humans and large wildlife in Africa, this conflict is managed in fruitless ways that only have the purpose to generate revenue within the strict elite circle of the trophy hunting industry, without solving the conflict issue. Alternative, science-based, non-invasive, cost-effective methods are scraped out because of the constructed idea that trophy hunting has to be part of any conservation protocol.
Projects that offer optimal alternatives to trophy hunting, in terms of improving the livelihoods of local communities, based on regenerative, climate-resilient practices and alternative conservation activities that reject and avoid violence, subjugation and extraction in favour of more ecologically sustainable and dignifying activities exist in countries in Africa, including Tanzania, South Africa, Namibia, Malawi, Zimbabwe, Zambia, Kenya, Uganda, Rwanda, Lesotho, Angola, Botswana, Eswatini, and Madagascar.
These practices promote fair share and equity, women and youth empowerment and self-sufficiency. These projects focus on improving farming productivity and food security via climate-smart agricultural practices they encourage economic development and wildlife coexistence and resilience. We are aware that these often activities struggle to flourish because of the competition with extractive, immediate-reward models and sectors which are plagued with corruption and nepotism as the hunting sector.
In Namibia, for example, more than 95% of trophy hunts are conducted on private land and only about 2 per cent in communal conservancies.[1] Hardly any financial revenue is derived from trophy hunting in these communities. Governments are not interested
In monitoring if revenues are allocated fairly. Furthermore, many locals feel excluded from the benefits their wildlife offers, since trophy hunting is a privilege of wealthy foreign tourists, while they themselves are mostly prohibited to hunt for subsidence. So instead of promoting economic independency and ensuring the livelihoods of local communities, trophy hunting deepens inequality and consolidates social injustice.
In July 2022, in a joint position statement on Trophy Hunting, 171 animal protection organisations, including 51 NGOs from Africa, asked for trophy hunting to be banned.
A recently published survey indicated that in South Africa the opposition to trophy hunting has increased from 64% in 2020 to 68% in 2022. The survey included data sourced from a diverse South African demographic across all provinces. The key findings from the IPSOS survey include:
68% of South Africans fully oppose or oppose to some extent the practice of trophy hunting – an increase from 56% in a similar 2018 survey.
65% of South Africans fully oppose or oppose to some extent the practice of canned lion hunting – an increase from 60% in a similar 2018 survey.
64% of South Africans disagree with the trophy hunting of elephants, rhinos, and leopards.
63% of South Africans disagree with the trophy hunting of lions.
66% of South Africans disagree with the trophy hunting of hippos.
60% of South Africans disagree with the trophy hunting of giraffes.
Regarding the 2022 hunting and export quotas announced by the Department of Forestry, Fisheries and the Environment (DFFE) in February 2022, 63% oppose the quota for 150 elephants, 62% oppose the quota for 10 black rhinos, and 61% oppose the quota for 10 leopards.
World Animal Protection recently commissioned research into public attitudes towards trophy hunting, surveying 10,900 people from around the world, including international tourists from countries who most frequently visit Africa. The research confirmed that international tourists want to see wildlife-friendly experiences and an end to trophy hunting. Tourists want to see wildlife alive and thriving and protected in a humane and ethical manner.
A study by the World Travel & Tourism Council confirmed that wildlife is worth more alive than dead. Another study of eight African countries by economists concluded that overall, tourism which relies heavily on wildlife contributed between 2.8% and 5.1% of GDP, and foreign trophy hunters made up less than 0.03% of the same GDP on average. Similarly, photo safaris, in comparison, allowed for sustainable, lucrative tourism activities without killing wildlife.The International Union for the Conservation of Nature Ethics Specialist Group wrote to the German government to ask for an end to the practice of trophy hunting imports for ethical, ecological and legal reasons. Professor Klaus Bosselmann, chair of the aforementioned group, said: “Trophy hunting unnecessarily threatens the survival and genetic integrity of protected species in the midst of the current crisis of the sixth mass species extinction. It is overdue that Germany, as the largest importer of hunting trophies in the EU, takes action.” Members of WAPFSA congratulate the German Ministry of the Environment, Steffi Lemke’s, announcement of their intention to restrict the import of hunting trophies from protected species in Germany.
WAPFSA also welcomed the announcement by IEG Italian Exhibition Group SpA in 2022 to discontinue Italy’s largest hunting fair in Vincenza in light of the fact that the event was incompatible with environmental values.
As one of the countries directly associated with the outdated colonial practice of trophy hunting, the United Kingdom has an obligation as well as an opportunity to take leadership position on this matter.
While some members of the scientific fraternity do support the old-styled trophy hunting model, it is true that this scientific fraternity is largely funded by trophy hunting outfitters, including Safari Club International. While we understand the arguments based on commercial justification for prolonging these colonialist practices, WAPFSA recognises that these arguments do not represent Nature’s best interests, which are calling for more respectful alternatives in support of responsible biodiversity management. These models do already exist, some of which are detailed in this submission.
The United Kingdom has a real opportunity to take a firm stand against the trophy hunting industry. WAPFSA, therefore, urges you to fulfil your government’s commitment by ensuring that the Bill is given sufficient parliamentary time to pass into law during the current parliamentary session and that any amendments aimed at weakening the Bill are robustly opposed.
1 Mucha Mkono (2019) Neo-colonialism and greed: Africans’ views on trophy hunting in social media, Journal of Sustainable Tourism, 27:5, 689-704, DOI: 10.1080/09669582.2019.1604719
2 C. MacLaren, J. Perche & A. Middleto, The value of hunting for conservation in the context of the biodiversity economy. REPORT – available at the link 2019-06-Hunting_report.pdf (resmob.org)
WAPFSA wrote a letter to the Minister of Forestry, Fisheries and the Environment with regard to Namibia’s decision to kill 86000 Cape Fur Seals for commercial purposes.
The decision has been taken by the Namibian government to slaughter 86000 Cape fur seals despite a decrease in demand for seal pups and the mounting opposition from conservationists. The brutal financially motivated killing of Cape fur seals in Namibia should be of concern to us all, because of the potential negative cascading effects on South African marine ecosystems.
One such negative effect relates to sharks. The International Union for Conservation of Nature (IUCN) has warned that 37.5% of the 1 200 known species of sharks are threatened with extinction. South Africa is a Party to the Convention on the Conservation of Migratory Species of Wild Animals, also known as the Convention on Migratory Species (CMS) with the objective to conserve migratory species throughout their ranges, including sharks that are listed in CMS Appendix I and II; according to CMS’s Article 2 and 2(2) and 2(3), (Parties) must take action,
“whenever possible and appropriate […] paying special attention to migratory species the conservation status of which is unfavourable and taking individually or in cooperation appropriate and necessary steps to conserve such species and their habitat [..] to avoid any migratory species becoming endangered; […] shall endeavour to provide immediate protection for migratory species included in Appendix I and […] shall endeavour to conclude agreements covering the conservation and management of migratory species included in Appendix II.
Namibia is one of a few countries that are “participating non-parties”to the CMS which implies that they are party to one or more of the agreements, and/or have signed one or more of the MOUs, for example, they have signed an MOU for the protection of the Atlantic Turtle.
The members of the Wildlife Animal Protection Forum South Africa (WAPFSA) recently prepared comments which were delivered to the South African Department of Forestry, Fisheries and the Environment (DFFE) on the Shark Biodiversity Management Plan, drafted in order to protect sharks. In direct contrast, Namibia’s Ministry of Fisheries approved a quota for the harvesting or culling of 80 000 seal pups and 6000 seal bulls to commence from the 1st of July 2023 and to continue till November. The Cape fur seal is one of the primary sources of food for many large sharks including the great white shark.
On the 11th of July 2023, WAPFSA issued a public statement on the planned killing of seals in Namibia (see also Annexure I). The statement questioned the non-transparent and unscientific decision-making process with regard to this cruel and unacceptable slaughter.
Two colonies of seals will be targeted during the planned slaughter period, the Cape Cross colony and the Walvis Bay colony, both near Swakopmund. Of further concern is that both of these areas have a history of Cape fur seal mass mortality. In 2020 and 2022, the phenomena of die-offs of the most common apex predator concerned local and international experts.
AN UNJUSTIFIABLE MASSACRE
According to scientific articles, the exploitation of seal body parts for trade in Southern Africa is a colonial relic dating back to the 17th century. Seals were slaughtered indiscriminately by sailors, for skins, meat and oil and for three centuries until 1899.
The slaughter in the modern day continues even though it is socially unacceptable and highly contested. The actual slaughter, paradoxically, takes place inside nature reserves; before sunrise, away from eyewitnesses, while the beaches are closed.
The Cape fur seals, who are not nocturnal mammals, are surprised in the dark or predawn. Terrified pups are rounded up, forcibly separated from their mothers, and violently beaten to death while the mothers watch from a short distance, and helplessly exchange mother–pup vocal highly distressed calls.
Scientific research has indicated that these marine mammals are sentient, alert and able to discriminate calls with high acoustic similarity and identify their offspring even in extremely large and numerous colonies. The call is the primary identification signal between mother and pup. Labourers are employed to club the pup to death or kill them with pick handles or shoot them. Pups get so terrified that they vomit their mothers’ milk in fear. Once the slaughter for the day is completed, the seal carcasses are piled up, taken away from the area by trucks and the blood is cleaned and removed before the oblivious tourists arrive.
CONCLUSION
The Cape Fur Seal, and associated predators, range across the oceans of Southern Africa. The Cape fur seal massacre in Namibia is promoted by short-sighted economic agendas, and it represents a threat to fragile local and extended ecosystems as well as to endangered species which are endemic to South Africa.
The unjustified massacre of the Cape fur seal raises huge ethical, animal and human welfare, well-being and environmental concerns.
The undersigning members of WAPFSA urge the DFFE Ministry to examine its objectives in terms of NEM:BA, to call for the protection of the Cape fur seal and to take all possible actions to halt stop this barbaric, unscientific and irresponsible massacre now, and to encourage long-term agreements to prevent this from happening in the future.
The Members of the Wildlife Animal Protection Forum of South Africa have expressed their concern in a letter regarding the Department of Forestry, Fisheries and the Environment’s capacity to host the monthly meetings of the Wildlife Well-Being Forum as recommended by Minister Barbara Creecy.
The Honourable Minister launched the WWBF on a live-streamed meeting on the 5th of May 2023, with the promise that there would be meaningful, ongoing consultation between the members of the Wildlife Well-Being Forum and the Department with the recommendation of organised monthly meetings.
A draft work plan was shared within the WWBF for comments in mid-May and a preliminary meeting was held on the 30th of May 2023. The agenda included the election of a Chair and the planning of monthly meetings to be discussed and diarised.
At the time, the DFFE expressed concerns about not having the capacity to fulfil this role, especially on a monthly basis. Some attendees took the view that DFFE should chair WWBF meetings while others suggested various solutions such as electing an alternative Chair. In closing, the Department made a commitment to organise and chair all future engagements stating that the next meeting would take place at the end of June 2023.
Despite this commitment by DFFE, no meetings were scheduled in June, July or August. Representatives of the various organisations have now been informed, after several follow-ups by some WAPFSA members, that the next WWBF engagement will only be scheduled for the 5th of September 2023.
Members of WAPFSA find this unacceptable, particularly given the pressing issues that need to be discussed.
The undersigning members of WAPFSA are concerned that the Department may not have the capacity for important engagement and consultation with our sector, which was a recommendation of the High-Level Panel in 2021 fully supported by the Minister.
If the Department does not have the capacity to chair these meetings with the frequency that is required, and as recommended by the Minister, the Department should allow alternative Chairs.
The Wildlife Animal Forum of South Africa was constituted with the objective of engaging with the Government on specific issues relevant to wildlife protection and well-being. WAPFSA is able to nominate a Chair from within its member ranks, who will have the necessary capacity to fulfil this role.
In addition, and related to the above, on the 19th May 2023, The Wildlife Animal Protection Forum South Africa (WAPFSA) sent the Honourable Minister a letter regarding the consultation processes. An urgent response to this letter is requested.
The Wildlife Animal Protection Forum South Africa is a community consisting of twenty-five South African wildlife and environmental conservation organisations that share common values, knowledge and objectives and who collectively comprise of a body of expertise from different sectors including but not limited to scientific, legal, welfare, rights, social justice, indigenous and public advocacy backgrounds.
Namibia’s Ministry of Fisheries has issued a quota for the harvesting or culling of 80 000 seal pups and 6000 seal bulls. Mr Romeo Muyunda, spokesperson for the Namibian Environment Ministry said: “If you let the seal population grow, they will consume the commercial amounts of fish.”
The Namibian Ministry has said that the harvesting of seals contributes to state revenue for national development programs. “Namibia’s seal population has increased to the point where they exceeded by far the carrying capacity of the environment therefore it is humane to curb the unrestricted seal population to a level where they can be sustained by the environment,” the government said in a statement.
THE CAPE FUR SEAL
The Cape Fur Seal is the most common seal species to be found in southern African waters. They occur from the Namibian west coast to East London on the east coast of South Africa. Their food consists mainly of shoaling pelagic fish such as pilchard, hake, Cape mackerel and snoek. They also eat squid and crustaceans. Cape Fur Seals are generalist feeders catching a wide variety of prey and are expected to feed on locally abundant prey species. Cape fur seals forage within 220km of their colony.
The uncontrolled exploitation of the Cape Fur Seal has previously led to a serious reduction in population numbers. In 1983 they were protected in South Africa by an Act of the Cape Parliament and harvesting was controlled until 1990 when it was finally prohibited. The protection of the seals and the halt to all sealing activities resulted in the recovery of the populations. Sealing continues in Namibia where it is still permitted. The effect of declining pelagic fish stocks on seal populations is a concern and the subject of several current research projects.
Every year quotas are set for the commercial “harvesting” or culling of the Cape Fur Seal in Namibia. Namibia is the only country in the Cape Fur Seal’s range in which commercial hunting is permitted. Sealing occurs on two mainland colonies, Cape Cross and Wolf/Atlas Bay.
THE SEAL HARVEST INDUSTRY
Seals are killed for their fur which was traded globally however there is a marked reduction in demand due to the European market ban on seal imports.
The Namibian harvesting season officially opened this year on the 1st of July 2023. Namibian seal products are now mainly exported to Asian markets, after twenty-seven countries, including the European Union, the United States of America, Mexico, and South Africa have banned the import of all seal products.
Of the Asian countries, the main market for Namibia’s seal cull has shifted to China. Seal penis is a delicacy enjoyed in China and seal fat is used in beauty products. According to a 2014 published report titled Grey Seal Management: Commercial use Opportunities and Challenges, Asian consumers, particularly athletes, consume a beverage called Dalishen Oral Liquid that is made from seal penis and testicles which they believe to be energizing and performance enhancing. The report also suggests that seal meat could be processed as meatballs, sausages, pate and an infinite range of entrees targeting gourmet food and wine clubs.
According to an article published in National Geographic in 2016, the oil derived from the blubber of the Cape Fur Seal advertised online as rich in Omega-3 fatty acids and allegedly is more readily absorbed by the human body given its mammalian source than fish oil. Since 2005, Namibia exported 33 000 gallons of seal oil, a third of which was exported to China.
Hatem Yavuz, the Namibian Honorary Consul to Turkey in 2012, was the main fur trader and buyer of seal skins from Namibia. According to an article published in 2014 he controlled 82 percent of the world’s seal fur trade.
The Hatem Yavuz Group is based in Turkey and Australia, it represented, according to an article published in 2016, the largest trade of any mammal out of Africa. An estimated 400 000 seal pelts from 2005 to 2015. According to Seven Network in Australia, the Yavuz Group controls 60 percent of the global market in seal products.
In 2020 and 2021 the brutal slaughter of the Cape Fur Seal was put on hold because of the global COVID-19 pandemic.
DON’T IGNORE THE SCIENTIFIC WARNINGS
In 2022 it was reported that hundreds of dead Cape Fur Seals had washed up on a stretch of Namibian coastline. Hundreds upon hundreds of dead seals littered the beaches at Pelican Point, a 5km colony situated in Walvis Bay. Scientists from Stellenbosch University and Sea Searchbelieved the cause of the death of these seals was linked to biotoxins namely domoic acid, produced by certain types of algae. The seals did not die of malnutrition, pollution, or exposure to noise according to the Namibian Dolphin Project.
In 2020 thousands of Cape Fur Seals died in what was termed an abortion storm. An unusual mortality event among one of the world’s largest seal colonies caused great concern among scientists. More than 5000 aborted Cape Fur Seal fetuses washed up on Central Namibia’s Pelican Point shore over a period of a few months.
The spike in deaths was far higher than normally witnessed a phenomenon that worried local and international experts. “If you are seeing die-offs of the most common apex predator in that ecosystem, we should not just be concerned about the seals, we should be concerned about the ecosystem and this event should be flashing big warning lights”.
Ecocide was defined as “Unlawful or wanton acts committed with knowledge that there is a substantial likelihood of severe and widespread or long-term damage to the environment being caused by those acts”.
Naude Dreyer, co-founder of Ocean Conservation Namibia Environmental Trust has expressed dismay over the lack of scientific research and decision-making based on demand. He has emphasized the potential disruption to the ecosystem caused by the removal of seal bulls.
Seals of Nam, a Namibian non-profit founded in 2010 with the goal of ending the country’s sealing industry is still hopeful that the ever-shrinking markets for seal products because of the global outcry against the mass killing of seals will eventually kill the industry.
Seal Protection Namibia a non-governmental organization is still seeking a ban on seal hunting on the grounds it is illegal and immoral.
Footage of the seals being clubbed to death has enraged animal rights campaigners for years. Terrified pups are rounded up, separated from their mothers, and violently beaten to death. The clubbing begins every morning at 6h00 am; then, at 9h00 am, the beaches have already been cleaned before the tourists arrive.
In 2012 Captain Pete Bethune founder of Earthrace Conservation witnessed the cull, and said: “It remains the most harrowing thing I have ever witnessed.” 2015 The Seals of Nam partnered with social media experts from the Seal Army in a global outcry against the annual Namibian seal hunt.
United Kingdom animal rights activist Ricky Gervais has joined other celebrities including George Lopez, Brigitte Bardot, Paul McCartney, Sara McLachlan, and Pamela Anderson who have condemned seal hunts in both Namibia and Canada. People for the Ethical Treatment of Animals has stated that the argument used by the Namibian government, protecting the fisheries because there is an issue of seal overpopulation, is invalid: “Studies have shown that overfishing is to blame”, with overfishing being the practice of fishing beyond what is allowed by permits, either at a rate that does not allow repopulation of species or by fishing untargeted species(bycatch) that are protected or threatened with extinction.
Studies indicate that overfishing is the primary cause of marine defaunation, while Illegal, Unreported, Unregulated fishing (IUU) is widely indicated by scientists as the cause of biodiversity loss, fish depletion and increased risks of shark and other endangered species extinction.
The Director of the conservation organization called, International Fund for Animal Welfare in South Africa, Jason Bell, commented on the proposed 2023 Namibian seal hunt “There is no justification for the killing, this is a purely political and economic issue, with very little concern for animal welfare.”
Seal Alert SA has expressed concerns about nursing seal pups being killed illegally. Namibia is the only country in the world that allows the killing of nursing seal pups. Seal Alert SA launched a bid in 2022 to interdict the seal cull. The Ombudsman’s office said that Seal Alert SA did not have a mandate to make recommendations to the Namibian government.
DESPITE THEMOUNTING OPPOSITION
Despite a decline in demand for seal pups and the mounting opposition from conservationists, the Namibian government has decided to continue with the annual cull.
WAPFSA Members hereby lend their unwavering support to all the organizations and individuals who have and continue to tirelessly defend the right to survival and the end to the abhorrent mass killing of the Cape Fur Seals in Namibia.
WAPFSA was initiated in 2017 as a collaborative network representing the interests of wild animals as a vehicle with which to engage governments on animal protection, ethical and compassionate conservation, welfare, and biodiversity loss issues amongst others.
The Cape Fur Seal, as well as its direct predators’ ranges, include the oceans of South Africa. We, therefore, agree that the protection of this mammal is of great importance to the continuance of a healthy aquatic ecosystem. We stand together on the shoulders of those before us, against the barbaric, unscientific and irresponsible, money-driven massacre of these mammals.
The Members of WAPFSA, who signed the aforementioned submission to the Deputy Director -General Ms Zintle Langa of the Department of Forestry, Fisheries and the Environment , belong to a community of diverse South African based organisations who share certain values, knowledge and objectives. WAPFSA members comprise of a body of expertise from different sectors including but not limited to scientific, environmental, legal, welfare, rights, social justice, indigenous and public advocacy backgrounds.
We are hopeful that the Department of Forestry, Fisheries and the Environment find this submission helpful because according the the International Union for Conservation of Nature (IUCN) 37.5 % of the 1200 species of sharks are currently threatened with extinction.
We are concerned that the Draft Shark Biodiversity Management Plan does not sufficiently and effectively address the reduction or the phasing out of the activities identified as major threats to the survival of shark species.
The Wildlife Animal Protection Forum South Africa (WAPFSA) is a network of diverse South African-based organisations that share certain values, knowledge and objectives and are comprised of expertise from different sectors including, but not limited to scientific, environmental, legal, animal welfare, animal rights, social justice, indigenous knowledge and public advocacy backgrounds.
On Friday 19th of May 2023 Members of WAPFSA wrote a letter to Minister Barbara Creecy. This is an excerpt from this communication:
WAPFSA thanks the Honourable Minister for establishing the Wildlife Well-being Forum.
In 2005, the Minister of Environment, Marthinus van Schalkwyk, established a consultative Wildlife Forum to engage quarterly with private entities about wildlife policy with the main objective being sustainable use. The Terms of Reference of this Forum were deliberately exclusive, discriminatory and exclusionary, thereby deliberately denying membership to other wildlife stakeholders including those working to protect and ethically conserve wild species within a one-health and welfare framework and striving to monitor and engage with all the issues discussed in the Wildlife Forum.
In February 2018 representatives of twenty-three wildlife and environmental protection organisations founded the Wildlife Animal Protection Forum South Africa (WAPFSA) and officially requested official acknowledgement from Minister for the Environment, Edna Molewa to engage with our sector.
However, not only were other stakeholders denied admission to this Forum, but no other parallel fora were established by the Government to evenly consult with other key interested and affected parties and stakeholders in the wildlife and biodiversity conservation and protection sector, despite continuous requests from the wildlife protection sector to be included.
The Wildlife Forum remains a limited and partial platform for stakeholder engagement which meets with government representatives behind closed doors to shape wildlife policy in South Africa. This has created a dysfunctional, inequitable and dualistic situation in relation to wildlife stakeholder engagement.
Following the recommendations of the High-Level Panel, in 2021, the process to establish a parallel forum, the Wildlife Well-being Forum, was initiated. We are pleased that this collaborative forum was finally launched on the 5th of May 2023, to include principles of inclusiveness, diversity, openness and transparency.
During the launch of the Wildlife Well-being Forum a member of WAPFSA, the EMS Foundation, raised the issue of perpetuated inequality when it became apparent that members of the exclusive Wildlife Forum have been invited to join the Wildlife Well-Being Forum. WAPFSA welcomes inclusivity, transparency, accountability and openness but we must insist that DFFE employs an equal and even-handed approach to stakeholder engagement.
The minutes of the Consultative Wildlife Forum are not publicly available even though government policy discussions and decisions relating to the sustainable use of South Africa’s biodiversity should be transparent. Members of WAPFSA have had to resort to the legal and time-consuming process of submitting a number of applications in terms of the Promotion of Access to Information Act 2 of 2000 (PAIA), to obtain such minutes. Response to various PAIA applications has returned with relevant parts of the Wildlife Forum minutes redacted – including member and organisational names – in order to try and omit information which is of public interest.
Our legislation states that the treatment and management of South African wildlife is a matter of public interest and all consultative meetings with the industry representatives should be open to all relevant stakeholders, Interested and Affected Parties and observers.
In addition, many of the organisations that work within the animal protection sector are also working within the wildlife conservation framework, indicating that conservation and protection are not two different and diverging sectors to be consulted separately and most importantly, under a different set of conditions.
The notion of public participation in all spheres of government is embedded in the Constitution of the Republic of South Africa. The Promotion of Administrative Justice Act, Act 3 of 2000 (PAJA) is also linked to public participation. Procedural fairness stipulates the necessity for a participatory process, PAJA necessitates a process of public participation through section 4 of the Act, which to its extent allows for more informed and defensible decisions with a greater potential of support by the public.
The National Policy Development Framework approved by Cabinet in 2020, highlighted that a number of laws were overturned by the courts because of technical deficiencies in their Constitutionality and the process of consultation. The policy framework recommended truly inclusive public participatory processes and made clear that “stakeholder consultation is non-negotiable and must strive for genuine stakeholder involvement rather than simple malicious compliance with the Constitution and other laws”.
In terms of Privacy, the treatment of personal information and personal interests in the public space, in the case Bernstein and Others v Bester NO and Others 1996 (4) BCLR 449 (CC); 1996 (2) SA 751 (CC), the Constitutional Court clearly established that: […] the fact that no right is to be considered absolute, implies that from the outset of interpretation, each right is always already limited by every other right accruing to another citizen. In the context of privacy, this would mean that it is only the inner sanctum of a person, such as his/her family life, sexual preference and home environment, which is shielded from erosion by conflicting rights of the community. This implies that community rights and the rights of fellow members place a corresponding obligation on a citizen, thereby shaping the abstract notion of individualism towards identifying a concrete member of civil society. Privacy is acknowledged in the truly personal realm, but as a person moves into communal relations and activities such as business and social interaction, the scope of personal space shrinks accordingly.’
The continued existence of the exclusive Wildlife Forum, which has historically operated in a bubble and behind closed doors, under a non-disclosure clause is unfair, unconstitutional, unnecessary and non-compliant with a number of laws, policies and guidelines.
As mentioned, during the public launch of the Wildlife Well-being Forum members of the Wildlife Forum have been given the opportunity to apply and join a more inclusive and transparent process. We respectfully, therefore, request the closure of the Consultative Wildlife Forum as established in 2005.
Alternatively, we ask that the Wildlife Forum be reconstituted to conform with the way that the Wellbeing Forum is constituted. To achieve this, industry representatives could observe Well-being Forum meetings but not participate and Well-being Forum representatives could observe Wildlife Forum meetings but not participate. This will promote transparency and efficiency while avoiding conflict during meetings.
WAPFSA also requests the unredacted disclosure of all minutes and records from the aforementioned Wildlife Forum for public scrutiny.
WAPFSA acknowledges and values the Honourable Minister’s continued efforts toward achieving fair processes and a more transparent and inclusive way to engage with stakeholders and civil society in relation to wildlife policy and we look forward to a positive and constructive working relationship with your department and other stakeholders.
WILDLIFE ANIMAL PROTECTION FORUM OF SOUTH AFRICA OPEN LETTER ADDRESSED TO THE LEADERS OF THE DEMOCRATIC ALLIANCE
The Wildlife Animal Protection Forum of South Africa is an alliance of twenty-four South African organisations that share certain values, knowledge and objectives and who collectively contribute to a body of expertise from the scientific, conservation, legal, welfare, rights, social and climate justice and public advocacy sectors.
The undersigned Members of WAPFSA and their colleagues in wildlife conservation hereby extend their congratulations and offer their official gratitude to the Democratic Alliance for their forward-thinking decision to adopt a policy resolution against the practice of captive or canned lion hunting, the breeding of lions for the intent of canned lion hunting and the breeding of lions for the sale of their bones and other derivatives.
Five years ago, in 2018, the 5th Parliamentary Committee on Environmental Affairs adopted a Report compiled during a two-day Colloquium on Captive Lion Breeding for Hunting in South Africa: Harming or Promoting the Conservation Image of the Country.
The Colloquium achieved an exceptionally high turnout, drawing speakers and participants from the captive lion breeding industry, hunting associations, conservation and animal protection organisations and the government.
Two members of WAPFSA presented the results of an eighteen-month investigation into the captive lion industry published in a Report titled: The Extinction Business: South Africa’s Lion Bone Trade.
According to the Report of the Portfolio Committee, which was later adopted by Parliament, there was a predominant view that the captive lion breeding industry did not contribute to conservation and was doing damage to South Africa’s conservation and tourism reputation.
The captive breeding of lions for hunting and lion bone trade came under severe criticism from both local and international conservation organisations for harming South Africa’s well-established and highly respected conservation image.
The then Portfolio Chairperson, Honourable Mr Philemon Mapulane, remarked that although South Africa is in favour of sustainable use of biodiversity resources, South Africa finds itself increasingly isolated at important international conservation platforms as a result of the captive lion industry. It seems as if South Africa’s conservation reputation is being compromised by this practice which does not seem to benefit the broader conservation, but a small number of breeders without proper scientific or conservation basis. Parliament, he warned must become particularly concerned when reputable conservation agencies such as the International Union for Conservation of Nature turn their backs and deplore these practices.
In May 2021 a Press Release, issued by the Parliamentary Communication Services on behalf of the Portfolio Committee on Environment, Forestry and Fisheries, Mr Fikile Xasa, stated that the Portfolio Committee welcomes the announcement made by the Minister of Environment, Forestry and Fisheries, that South Africa plans to ban the breeding of lions in captivity for trophy hunting or for tourists to pet.
The Chairperson of the committee, Mr Fikile Xasa said: “It was indeed satisfying to have attended the launch of the Report of the High-Level Panel that agreed with our parliamentary resolution to consider banning this destructive practice for the greater public good, our conservation brand and the dependant tourism industry. As public representatives, we feel our people have been heard.”
We are relying upon the Democratic Alliance to continue to be a strong voice in order to strengthen the enforcement of the closure of this abhorrent industry in order to save and preserve South Africa’s conservation reputation and to preserve lion populations in the wild for future generations.
SIGNED BY THE FOLLOWING MEMBERS OF THE WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA AND COLLEAGUES IN WILDLIFE CONSERVATION:
Mr Henry Smith, MP Crawley Constituency House of Commons, London Will Travers OBE, Co-Founder and Executive President Born Free Foundation Richard Peirce, Author “Cuddle Me, Kill Me”, Investigator “Lions, Bones & Bullets” Eduardo Goncalves, Founder of the Campaign to Ban Trophy Hunting John Read, International Director Campaign to Ban Trophy Hunting Daniela Freyer, Co-Founder Pro Wildlife e.V. Dr Barbara Maas, Founder and Chief Executive, People for Nature and Peace
Sairusha Govindsamy, Climate Program, African Climate Alliance, South Africa Dave Du Toit, Founder, Vervet Monkey Foundation, South Africa Fiona Miles, Director, Four Paws (SA) Jabu Myeni, Env, Education Programme, Gifted for Good, South Africa Les Mitchell, Director, Institute for Critical Animal Studies (Africa) Lex Abnett, Director, Southern African Fight for Rhinos, South Africa Linda Tucker, CEO Founder, Global White Lion Protection Trust, South Africa Lizaene Cornwall and Catherine Nyquist, Co-Founders, Panthera Africa Big Cat Sanctuary, South Africa Megan Carr, Founder, Rhinos in Africa, South Africa Michele Pickover, Executive Director, EMS Foundation, South Africa Renee Bish and Peter Oxford, Co-Founders, Betty’s Bay Baboon Action Group, South Africa Sera Farista, Climate Justice Campaigner, Youth Climate Group, South Africa Smaragda Louw, Director, Ban Animal Trading, South Africa Stefania Falcon, Co-Founder, Future 4 Wildlife, Africa Stephen Fritz, Indigenous Leader, South Peninsula Khoi Council, South Africa Stephen Munro, Director, Centre for Animal Rehabilitation and Education, South Africa Steve Smit, Co-Founder, Monkey Helpline, South Africa Toni Brockhoven, Chairperson, Beauty Without Cruelty (South Africa) Vivien Law, Regenerative Farming Program, Parliament for the People, South Africa Wynter Worsthorne, Founder of Animal Talk Africa, South Africa
The Department of Environmental Affairs acknowledged receipt of the Appeal submitted by Members of WAPFSA on the 10th of May 2023.
WAPFSA registered as an Interested and Affected Party and has previously submitted preliminary comments to the Draft Scoping Report and the Members of WAPFSA have also submitted comments on the Environment and Social Impart Assessment.
Members of the Wildlife Animal Protection Forum South Africa delivered a submission with their comments on the Draft Cape Peninsula Baboon Strategic Management Plan on Friday 31st March 2023.
The Plan should be titled: CAPE PENINUSULA HUMAN-BABOON CO-EXISTENCE STRATEGIC MANAGEMENT PLAN (HBCEMP) this will speak to a more useful framework to help support more sustainable people-nature interactions in the context of the conservation of African baboons to achieve human-baboon coexistence, by balancing the integrity of nature with human wellbeing. A new ethos is necessary to ensure changes not only to what is done but how things are done. The MP should be based on Ubuntu and within the context of changing people’s attitudes to Nature and wild species so that they understand that their conservation is essential to the long-term flourishing of humanity and aspire to co-exist harmoniously within Nature instead of simply regarding wild species as merely economic “resources” or “damage-causing”.
WAPFSA believes that this merits a separate goal (Ubuntu and harmonious co-existence within Nature are promoted) which focuses on how conservation will be undertaken in future, with an emphasis on applying ethics such as Ubuntu to change how people view, and relate to Nature, and to contribute to ways for people to co-exist with wild species so that life in all its diversity can be sustained and that human wellbeing is increased as a consequence of protecting and restoring natural ecosystems instead of at their expense.
The Plan cannot be developed in a vacuum. It therefore must include a preface which provides the overarching context and background in relation to South Africa’s primate populations including the lack of credible data, the urgent need for a population census, regulation and oversight insufficiencies and the outdated legislative framework (both provincially and nationally) – for example, sections of the Western Cape Biodiversity Act have not come into effect, particularly the Ordinance has not been repealed and this relates specifically to the status and killing of baboons. Please take note of the contents and findings of this 2023 research report on South Africa’s nonhuman primates:
Transformational changes (game-changing shifts) are urgently needed if we are to secure humanity’s future. To do this we need to address the interlinked emergencies of human-induced climate change and the loss of wild species. What is needed is a progressive vision and policy for conservation based on the ethic of Ubuntu and the recognition that humanity can only flourish in the long term by conserving the natural systems that support all life and finding ways to coexist in harmony with Nature.
Conservation policies and decisions must be guided primarily by ecological and welfare considerations, i.e. decisions about wild species and biodiversity must be based on ecological considerations (e.g. what is best for the ecosystem) and welfare considerations (e.g. treating wild animals with respect and without cruelty both for their own sakes and to foster consideration for other species in accordance with the ethic of Ubuntu.
WAPFSA notes that some organisations are of the opinion that the entire BSMP process is flawed and illegal. This needs to be taken seriously and investigated by the JMC to determine if all the necessary steps in this process were correctly followed.
WAPFSA wants to place on record that there are transparency and accountability concerns as stakeholders were not provided with the Terms of Reference of the CPBMJTT or the Memorandum of Agreement between the three parties. These are essential documents to verify policy, budget, or resources, amongst other things, from and between the three spheres of government involved. In addition, stakeholders were never informed of the criteria for the selection of the members of the CPBMJTT and had no opportunity to comment on such criteria.
WAPFSA requests that any changes to the existing Baboon Management programme be consultative and inclusive of all stakeholders.
WAPFSA is concerned that the City of Cape Town (“COCT”) Urban Baboon Programme is to be terminated in June 2023 with apparently no plan in place to ensure the safety and well-being of the Peninsula baboons. If the programme is resumed, WAPFSA is of the view that the protocols for the monitoring of baboons needs to be re-examined and re-imagined, through wide stakeholder consultation.
WAPFSA urgently requests a moratorium on the killing of baboons while the Management Plan is being amended, updated, consulted on, and implemented.
Image Credit: Jenny ParsonsPringle Bay, South Africa
Jagd und Hund Hunting Fair in Dortmund, Germany (Image Credit worldanimalsvoice.com 2022)
AN AFRICAN PERSPECTIVE ON THE NEGATIVE IMPACTS OF THE COLONIAL-STYLED COMMERCIALISATION OF ENDANGERED WILDLIFE SPECIES ADVERTISED AT JAGD UND HUND, IN DORTMUND IN GERMANY
24TH – 29TH JANUARY 2023
Advertised is the largest most prestigious shopping paradise for hunters, the 41st Jagd Und Hund is a trade show held annually in Dortmund in Germany, this year the show will be take place from the 24th to the 29th of January 2023.
Tens of thousands of animals are hunted and killed by hunters who pay handsomely for this pleasure. Many European and British citizens are losing the appetite to continue to support or participate in the colonial sport of trophy hunting.
This is an open letter written to the Mayor of Dortmund which has been signed by members of WAPFSA, members of the Pro Elephant Network and endorsed by a number of world renown wildlife conservationists, wildlife veterinarians, international dignitaries, politicians and environmental lawyers.
Members of the Wildlife Animal Protection Forum Formally Distance Themselves from WILDCHOICES
A formal communication was delivered to the owners of WildChoices and the South African Tourism Services Association on Wednesday 7th of December 2022.
The Wildlife Animal Protection Forum South Africa (WAPFSA), is a network of thirty-one diverse South African NGOs that share certain values, knowledge and objectives, and that collectively comprise a body of expertise in various fields in South Africa, from scientific, conservation, and welfare, rights, tourism, social justice, indigenous rights, public advocacy sectors and the law.
The South African Tourism Services Association (SATSA) is a member-driven, non-profit association representing the private sector. In 2018 SATSA established a Board Committee on Captive Wildlife Interactions and commissioned BDO South Africa, an independent consulting firm, to:
Define the types of entities that fall within the ambit of captive wildlife interactions including standardising definitions and terminology;
Develop an ethical framework to evaluate operations that involve captive wildlife interactions to underpin the debate and establish the principles upon which the ethicalness of animal interaction operations may objectively be evaluated; and,
Develop a set of guidelines for the self-regulation of captive wildlife interaction tourism experiences.
In November 2019 SATSA published their Captive Wildlife Attractions and Activities Guidelines and Decision Tool which is endorsed by a number of organisations.
Apparently, in 2021, two members of the 2018 SATSA Board Committee, Brett Mitchell and Gavin Reynolds founded WildChoices which is owned by Wildly Adventures (Pty) Ltd (reg No: 2020/635217/07), to identify and assess all the captive wildlife interaction facilities in South Africa using the SATSA Guidelines and Decision Tool.
According to the information on the website: ‘WildChoices assists local and international tour operators, agents, and individual travellers to make informed, ethical choices about captive wildlife tourism facilities in South Africa’. WildChoices employs the SATSA Decision Tree to make its assessments. After receiving complaints about various listings on the WildChoices website, WAPFSA conducted internal research and discovered numerous potentially problematic listings, for example, WildChoices has listed zoos, petting zoos and facilities that have traded wild animals as places to “support with caution”.
WAPFSA organisations do not support the captive wildlife industry, especially where animals are utilised for entertainment and/or breeding for trade. It is an additional concern that animal welfare issues and trophy hunting are not considered in the SATSA Decision Tree.
As testimony to the fact that this Tool is faulty and inaccurately applied, a Member of WAPFSA has been wrongly listed on the WildChoices’ website. To be more specific, the Global White Lion Protection Trust (“GWLPT”) has been listed as a facility “to avoid”. GWLPT is a non-profit, non-commercial organisation, and not a tourist facility – and therefore does not qualify for listing in the first place. Some of our members have objected to this inaccuracy to WildChoices and have asked specific questions of relevance, which have not been answered by WildChoices.
Until such time as these errors are corrected and the Tool is vetted by WAPFSA as a valid measure of unethical establishments, we as a forum cannot support or be associated with this initiative. We therefore formally distance ourselves from the WildChoices listing.
